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Federal Agencies Have Taken Some Actions to Respond to and Lessen
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Report to the Ranking Member, Committee on Environment and Public
Works, U.S. Senate:
United States Government Accountability Office:
GAO:
August 2010:
Perchlorate:
Occurrence Is Widespread but at Varying Levels; Federal Agencies Have
Taken Some Actions to Respond to and Lessen Releases:
GAO-10-769:
GAO Highlights:
Highlights of GAO-10-769, a report to the Ranking Member, Committee on
Environment and Public Works, U.S. Senate.
Why GAO Did This Study:
Perchlorate is both a man-made and naturally occurring chemical. It is
used in rocket fuel, explosives, fireworks, and other products.
Naturally occurring perchlorate is produced through atmospheric
processes and then settles on surface water or land. Perchlorate can
disrupt the uptake of iodide in the thyroid, potentially interfering
with thyroid function and negatively affecting fetal and infant brain
development and growth. As of June 2010, there is no federal
regulatory standard for perchlorate in drinking water, and the
Environmental Protection Agency (EPA), which has the authority to
regulate contaminants in public drinking water systems, had not
determined whether to establish one. The Department of Defense (DOD),
the National Aeronautics and Space Administration (NASA), and the
Department of Energy (DOE) are the primary federal users of
perchlorate.
GAO was asked to examine (1) what is known about the extent to which
perchlorate occurs in the nation’s water and food supply and its
likely sources; (2) what actions DOD, NASA, and DOE have taken to
respond to or lessen perchlorate releases; and (3) what actions
states, such as California and Massachusetts, have taken to regulate
perchlorate. To address these questions, GAO analyzed data from EPA,
DOD, NASA, and DOE, reviewed agency documents, and interviewed federal
and state officials, researchers, and others.
What GAO Found:
Perchlorate has been found in water and other media at varying levels
in 45 states, as well as in the food supply, and comes from a variety
of sources. EPA conducted one nationwide perchlorate sampling, between
2001 and 2005, and detected perchlorate at or above 4 parts per
billion in 160 of the 3,865 public water systems tested (about 4.1
percent). In 31 of these 160 systems, perchlorate was found above 15
parts per billion, EPA’s current interim health advisory level.
Sampling by DOD, NASA, and DOE detected perchlorate in drinking water,
groundwater, surface water, soil, and sediment at some facilities. For
example, GAO’s analysis of DOD data showed that perchlorate was
detected at almost 70 percent of the 407 installations sampled from
fiscal years 1997 through 2009, with detections ranging from less than
1 part per billion to 2.6 million parts per billion. A 2006 Food and
Drug Administration study found perchlorate in 74 percent of 285 food
items tested, with certain foods, such as tomatoes and spinach, having
higher perchlorate levels than others. According to researchers,
concentrations of perchlorate at or above 100 parts per billion
generally result from activities involving man-made perchlorate, such
as the use of perchlorate as a rocket propellant. Lower concentrations
can result from the use of man-made perchlorate, atmospheric
processes, or the use of fertilizer containing naturally occurring
perchlorate.
According to DOD, NASA, and DOE officials, the agencies have sampled,
monitored and, at several sites, begun cleaning up perchlorate. When
DOD detects perchlorate at or above threshold levels—currently 15
parts per billion for water—DOD is to investigate further and may take
additional actions. DOD has taken actions beyond initial sampling at
48 of the 53 installations with perchlorate detections above 15 parts
per billion. NASA is in the midst of a cleanup at the Jet Propulsion
Laboratory in California and is monitoring the level of perchlorate in
groundwater at three other facilities. In addition, DOE is cleaning up
perchlorate at two facilities involved in high explosives research,
development, and testing and is monitoring the level of perchlorate in
groundwater at two other facilities. According to DOD, NASA, and DOE
officials, the perchlorate detected at their facilities is largely the
result of past disposal practices. Officials at these agencies told us
that by complying with current federal and state waste disposal laws
and regulations, they have lessened their perchlorate releases. In
addition, DOD is developing perchlorate substitutes for use in weapons
simulators, flares, and rockets.
In the absence of a federal regulatory standard for perchlorate in
drinking water, California and Massachusetts have adopted their own
standards. California adopted a drinking water standard of 6 parts per
billion in 2007, and Massachusetts set a drinking water standard of 2
parts per billion in 2006. The key benefits of a regulatory standard
cited by state officials include protecting public health and
facilitating cleanup enforcement. However, limited information exists
on the actual costs of regulating perchlorate in these states. Also,
at least 10 other states have established guidance levels for
perchlorate in drinking water (ranging from 1 to 18 parts per billion)
or in groundwater.
What GAO Recommends:
This report contains no recommendations.
View [hyperlink, http://www.gao.gov/products/GAO-10-769] or key
components. For more information, contact John Stephenson at (202) 512-
3841 or stephensonj@gao.gov.
[End of section]
Contents:
Letter:
Background:
Perchlorate Occurs Nationwide at Varying Levels, and the Sources Are
Sometimes Difficult to Determine:
DOD, NASA, and DOE Have Sampled for Perchlorate, Begun Cleanup Actions
at Some Sites, and Taken Steps to Lessen Releases:
In the Absence of a Federal Standard, Some States Have Set Drinking
Water Standards and Guidance Levels for Perchlorate:
Agency Comments and Our Evaluation:
Appendix I: Objectives, Scope, and Methodology:
Appendix II: National Priorities List Sites Where Perchlorate Has Been
Identified as a Contaminant of Concern:
Appendix III: Actions Taken by DOD at Installations with Perchlorate
Detections above 15 Parts per Billion:
Appendix IV: Comments from the Department of Defense:
Appendix V: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: Summary of State Guidance Levels for Perchlorate in Drinking
Water:
Table 2: Summary of State Guidance Levels for Perchlorate in
Groundwater:
Figures:
Figure 1: UCMR 1 Public Drinking Water Systems with Perchlorate
Detections, 2001-2005:
Figure 2: Maximum Perchlorate Concentrations Reported in Any Media as
of October 2009:
Abbreviations:
CERCLA: Comprehensive Environmental Response, Compensation, and
Liability Act of 1980:
DOD: Department of Defense:
DOE: Department of Energy:
EPA: Environmental Protection Agency:
FDA: Food and Drug Administration:
NASA: National Aeronautics and Space Administration:
NRC: National Research Council:
OEHHA: Office of Environmental Health Hazard Assessment:
RCRA: Resource Conservation and Recovery Act:
UCMR 1: Unregulated Contaminant Monitoring Rule 1:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
August 12, 2010:
The Honorable James M. Inhofe:
Ranking Member:
Committee on Environment and Public Works:
United States Senate:
Dear Senator Inhofe:
Perchlorate is both a man-made and naturally occurring chemical. It is
manufactured for use as an oxidizer[Footnote 1] in solid rocket fuel,
munitions, explosives, fireworks, road flares, and other products. It
also occurs naturally and is found in certain fertilizers. Perchlorate
can disrupt the uptake of iodide in the thyroid, potentially
interfering with thyroid function and negatively affecting fetal and
infant brain development and growth. Because of concerns over these
and other potential health impacts, some states, water utilities, and
Members of Congress have urged the U.S. Environmental Protection
Agency (EPA) to set a federal drinking water standard for perchlorate.
The Department of Defense (DOD), the National Aeronautics and Space
Administration (NASA), and the Department of Energy (DOE) are the
primary federal users of perchlorate.
In response to your request for information on perchlorate, this
report examines (1) what is known about the extent to which
perchlorate occurs in the nation's water and food supply and its
likely sources; (2) what actions DOD, NASA, and DOE have taken to
respond to or lessen perchlorate releases; and (3) what actions
states, such as California and Massachusetts, have taken to regulate
perchlorate. To determine what is known about the extent of
perchlorate occurrence in the nation's water and food supply and its
likely sources, we analyzed perchlorate occurrence data provided by
EPA, DOD, NASA, and DOE and interviewed federal and state agency
officials, researchers, industry representatives, and others. To
determine what actions DOD, NASA, and DOE have taken to respond to or
lessen perchlorate releases, we analyzed agency data, reviewed agency
documents, and interviewed agency officials and federal and state
environmental officials. We visited selected DOD and NASA facilities
to discuss and observe their activities related to perchlorate
cleanup, including Edwards Air Force Base (DOD), Redstone Army Arsenal
(DOD), the Jet Propulsion Laboratory (NASA),[Footnote 2] and the
Marshall Space Flight Center (NASA). We selected sites identified by
EPA, DOD, and NASA officials as illustrative of their perchlorate
response actions. To determine what actions California and
Massachusetts have taken to regulate perchlorate, we reviewed state
documents and interviewed state officials. In addition, we reviewed
documents and interviewed officials in states that have set advisory
levels and public health goals for perchlorate. We also interviewed
EPA regional officials about state actions related to perchlorate.
We assessed the reliability of the DOD data that we used by
electronically testing for obvious errors in accuracy and
completeness, reviewing information about the data and the systems
that produced them, and interviewing agency officials knowledgeable
about the data. When we found inconsistencies in the data, we worked
with DOD officials to clarify them before conducting our analyses. We
also assessed the procedure used to collect the EPA data we used. We
determined that both the DOD and EPA data were sufficiently reliable
for the purposes of this report. We conducted our work from July 2009
to August 2010 in accordance with all sections of GAO's Quality
Assurance Framework that are relevant to our objectives. The framework
requires that we plan and perform the engagement to obtain sufficient
and appropriate evidence to meet our stated objectives and to discuss
any limitations in our work. We believe that the information and data
obtained, and the analysis conducted, provide a reasonable basis for
any findings and conclusions in this product. See appendix I for a
more detailed description of our objectives, scope, and methodology.
Background:
Man-made perchlorate is primarily produced as ammonium perchlorate for
use as an oxidizer in solid rocket fuels, fireworks, explosives, and
road flares. Perchlorate can also be present as an ingredient or as an
impurity in such items as matches, lubricating oils, aluminum
refining, rubber manufacturing, paint and enamel manufacturing, and
leather tanning and as an ingredient in bleaching powder used for
paper and pulp processing. Further, perchlorate can develop as a by-
product of sodium hypochlorite (i.e., bleach) solutions used as
disinfectant in water and wastewater treatment plants when these
solutions are stored for a long period of time. Naturally occurring
perchlorate is produced through atmospheric processes and then settles
on surface water or land as precipitation or dry deposits. Perchlorate
also exists as a natural impurity in nitrate salts from Chile, which
are imported and used to produce nitrate fertilizers and other
products.
EPA has the authority to regulate contaminants, such as perchlorate,
in public drinking water systems. Under the Safe Drinking Water Act,
as amended,[Footnote 3] when EPA decides to regulate a contaminant,
its determination must be based on findings that (1) the contaminant
may have an adverse health effect, (2) the contaminant is known to
occur or there is substantial likelihood that the contaminant will
occur in public water systems with a frequency and at levels of public
health concern, and (3) in the sole judgment of the Administrator,
regulation of the contaminant presents a meaningful opportunity for
reducing health risks for persons served by public water systems.
History of EPA's Investigation and Study of Perchlorate:
Perchlorate was initially identified by EPA as a potential contaminant
in 1985, when it was found in wells at hazardous waste sites in
California. In 1992, EPA issued a provisional reference dose[Footnote
4] for perchlorate equivalent to a concentration of 4 parts per
billion in drinking water[Footnote 5] and, in 1995, issued a revised
provisional reference dose with a drinking water equivalent ranging
from 4 to 18 parts per billion.[Footnote 6] These reference doses were
considered provisional by EPA because they had not undergone internal
or external peer review. However, EPA and state regulators could use
them to establish guidance levels for cleaning up contaminated
groundwater. A more sensitive perchlorate detection method became
available in 1997, and more states began detecting perchlorate in
drinking water, groundwater, and surface water.
In 1998, EPA published its first draft assessment of perchlorate
exposure health risks and placed perchlorate on its Contaminant
Candidate List--a list of contaminants that may require regulation
under the Safe Drinking Water Act. In 1999, under Unregulated
Contaminant Monitoring Rule 1 (UCMR 1), EPA required all public
drinking water systems serving more than 10,000 people and 800
representative public water systems serving 10,000 or fewer people to
monitor their drinking water systems for perchlorate over a 12-month
period and to report the results.[Footnote 7] Also, in 1999, an
external panel of independent scientists reviewed EPA's draft risk
assessment and recommended additional studies and analyses to provide
more data on perchlorate and its health effects. DOD and industry
researchers conducted such studies and submitted them to EPA. Based on
an analysis of these studies, EPA revised its draft perchlorate risk
assessment and released it for peer review and public comment in
January 2002. The revised draft risk assessment included a proposed
reference dose equivalent to a concentration of 1 part per billion in
drinking water. DOD, industry, and some members of the scientific
community disagreed with EPA's draft risk assessment and its
conclusions, including the proposed reference dose. The scientific
controversy involved, among other things, the adequacy and relevance
of available human data for assessing health risks, the quality and
validity of some animal data, the definition of adverse health effect,
and the application of uncertainty factors.
After a second peer review, and in light of the criticisms from some
scientists surrounding the concentration at which perchlorate presents
a human health risk, DOD, NASA, DOE, and EPA asked the National
Academy of Sciences, in 2003, to review the available science and
EPA's draft health risk assessment. In January 2005, the Academy's
National Research Council (NRC) recommended a reference dose for
perchlorate exposure of 0.0007 milligrams per kilogram of body weight
per day.[Footnote 8] EPA calculated the drinking water equivalent of
this dose to be 24.5 parts per billion. EPA adopted the reference dose
and, in January 2006, directed its regional offices to use 24.5 parts
per billion as a preliminary remediation goal[Footnote 9] when
assessing sites for cleanup under the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) of 1980[Footnote
10] and the National Oil and Hazardous Substances Pollution
Contingency Plan, the regulation that implements CERCLA.
In October 2008, EPA issued a preliminary determination not to
regulate perchlorate and requested public comment on its findings that
perchlorate occurs infrequently at levels of health concern in public
water systems and that there was not a "meaningful opportunity for
health risk reduction" through a national drinking water regulation.
In response to stakeholder comments that provided additional
scientific evaluation of the information EPA used to make its
preliminary determination, EPA announced, in January 2009, that it
planned to seek additional input from NRC on assumptions regarding the
possible effects of perchlorate on infants and young children. Around
the same time, EPA's Office of Water published an interim health
advisory for perchlorate that includes a health advisory level of 15
parts per billion. This interim health advisory level takes into
account exposure from food, as well as drinking water, for pregnant
women and their fetuses (the most sensitive life stage identified by
NRC). The advisory provides informal technical guidance to assist
state and local officials in protecting public health where
perchlorate contamination of drinking water has occurred, while EPA
evaluates the opportunity to reduce risks through a national drinking
water standard. Following the establishment of the interim health
advisory, EPA's Office of Solid Waste and Emergency Response withdrew
its preliminary remediation goal for perchlorate of 24.5 parts per
billion. In its place, EPA recommended the interim health advisory
level of 15 parts per billion be used as the preliminary remediation
goal when assessing sites for cleanup under CERCLA.
In August 2009, EPA published a notice that it would not seek
additional input from NRC and instead was seeking public comment on
additional approaches for interpreting the available data on the level
of health concern, the frequency of occurrence of perchlorate in
drinking water, and the opportunity for health risk reduction through
a national drinking water standard. In April 2010, EPA's Office of
Inspector General released a report that reviewed and critiqued the
risk assessment process and procedures used by EPA to develop and
derive the perchlorate reference dose.[Footnote 11] As of July 2010,
EPA had not yet made a final decision whether to establish a
regulatory standard for perchlorate in drinking water.
Requirements for Federal Agencies Related to Perchlorate:
Several federal laws impose requirements on federal agencies related
to monitoring, reporting, and cleanup of hazardous substances,
pollutants, and contaminants such as perchlorate.
* CERCLA, as amended, better known as Superfund, requires responsible
federal agencies to identify and assess releases of hazardous
substances such as perchlorate[Footnote 12] and to follow CERCLA
requirements in their cleanup, among other things. The CERCLA process
typically follows a series of steps, which may include investigations,
human health risk assessments and ecological risk assessments,
evaluation and selection of cleanup approaches, and implementation of
the cleanup, known as a remedial action.
* CERCLA itself does not establish cleanup standards. Rather, the
remedial action chosen by a federal agency must meet applicable or
relevant and appropriate requirements based on standards for
contaminants set under state or federal laws or regulations and in
consideration of other guidance.[Footnote 13] If there is no such
requirement for a given contaminant, the agency must still achieve a
degree of cleanup, which, at a minimum assures protection of human
health and the environment. Both existing and potential sources of
drinking water are generally to be considered in assessing risk and in
selecting a remedy.[Footnote 14]
* In general, EPA is the lead regulator for all sites on EPA's list of
some of the most contaminated sites in the country--the National
Priorities List--which are commonly referred to as Superfund sites.
State environmental agencies may be the lead regulator at other sites.
* Executive Order 12580 delegated certain CERCLA response authorities
to federal agencies.[Footnote 15] In particular, DOD and DOE each have
lead response agency authority for properties under their respective
jurisdictions, which they are to exercise consistent with CERCLA
section 120 governing federal facilities.
* The Superfund Amendments and Reauthorization Act established the
Defense Environmental Restoration Program in 1986 and directs DOD to
clean up releases of hazardous substances, such as perchlorate, at
active DOD installations and formerly used defense sites in accordance
with CERCLA.[Footnote 16]
* The Resource Conservation and Recovery Act (RCRA), as amended,
requires federal agencies generating, treating, or disposing of
hazardous wastes, including hazardous wastes containing perchlorate,
to obtain permits and/or to comply with regulations applicable to the
management of such wastes.[Footnote 17]
* Pursuant to its responsibilities under the Safe Drinking Water Act,
in 1999, EPA promulgated the UCMR 1, which required entities,
including federal agencies, operating large and selected small public
water supplies to monitor their drinking water systems for perchlorate
and other contaminants over a 1-year period and to report the
results.[Footnote 18]
* The Clean Water Act requires federal agencies discharging pollutants
into surface waters--such as from a wastewater treatment facility--to
obtain a National Pollutant Discharge Elimination System permit from
EPA and comply with its discharge limitations.[Footnote 19]
* Pursuant to RCRA and the Safe Drinking Water Act, EPA can issue
perchlorate abatement orders to federal facilities where there is an
imminent and substantial endangerment to health and other conditions
are met.
Since 2002, DOD has issued a series of perchlorate policies. Most
recently, in April 2009, DOD issued a policy on perchlorate release
management that directs the military services to, among other things,
address perchlorate in the same manner that the services address other
contaminants of concern. The policy adopts EPA's preliminary
remediation goal for perchlorate of 15 parts per billion in water
where (1) there is an actual or potential drinking water exposure
pathway[Footnote 20] and (2) no legally applicable or relevant and
appropriate requirements exist under federal or state laws. NASA and
DOE have issued no policies that focus exclusively on perchlorate,
according to agency officials.
Perchlorate Occurs Nationwide at Varying Levels, and the Sources Are
Sometimes Difficult to Determine:
The full extent of perchlorate occurrence is unknown because there is
no national system to track detections. However, perchlorate has been
found at varying levels across the nation in water and the food supply
and is known to come from a variety of sources. While the sources of
perchlorate at or above 100 parts per billion in the environment are
generally the result of defense-related or manufacturing activities,
sources of concentrations below that level can be difficult to
determine.
Although the Full Extent of Perchlorate Occurrence Is Unknown, It Has
Been Detected at Varying Levels in Drinking Water and Other Media in
45 States:
There is no national system to track perchlorate detections, so the
full extent of perchlorate occurrence nationwide is unknown. In 2005,
we recommended that EPA establish a formal structure to centrally
track and monitor perchlorate detections.[Footnote 21] EPA officials
disagreed with our recommendation, saying that the agency already had
sufficient information on perchlorate concentrations in various
environmental media that indicated the extent of contamination
nationally and that if EPA were to implement a tracking system, the
agency would require additional resources. However, as our report
noted, without a formal system to track and monitor perchlorate
findings and cleanup activities, EPA and the states do not have the
most current and complete accounting of perchlorate as an emerging
contaminant of concern, including the extent of perchlorate found and
the extent or effectiveness of cleanup projects.
Although there has been no nationwide sampling for perchlorate
recently, nationwide sampling under EPA's UCMR 1, which occurred
between 2001 and 2005, detected perchlorate at or above 4 parts per
billion in at least one sample in approximately 4.1 percent of the
public drinking water systems tested. According to EPA data,
perchlorate was reported in 160 of 3,865 public drinking water
systems, with detections ranging from 4 to 420 parts per billion.
Thirty-one of the 160 systems, or about a fifth, had detections above
15 parts per billion--EPA's current interim drinking water health
advisory level. Figure 1 shows the number of public water systems with
perchlorate detections and the maximum concentration detected,
according to EPA's data.
Figure 1: UCMR 1 Public Drinking Water Systems with Perchlorate
Detections, 2001-2005:
[Refer to PDF for image: vertical bar graph]
Maximum perchlorate concentration (parts per billion): 4 to less than
8;
Number of Systems: 93.
Maximum perchlorate concentration (parts per billion): 8 to less than
12;
Number of Systems: 23.
Maximum perchlorate concentration (parts per billion): 12 to less than
16;
Number of Systems: 13.
Maximum perchlorate concentration (parts per billion): 16 to less than
20;
Number of Systems: 10.
Maximum perchlorate concentration (parts per billion): 20 to less than
24;
Number of Systems: 6.
Maximum perchlorate concentration (parts per billion): 24 to less than
28;
Number of Systems: 2.
Maximum perchlorate concentration (parts per billion): 28 to less than
32;
Number of Systems: 2.
Maximum perchlorate concentration (parts per billion): 32 to less than
36;
Number of Systems: 5.
Maximum perchlorate concentration (parts per billion): 36 to less than
40;
Number of Systems: 1.
Maximum perchlorate concentration (parts per billion): 40 or more;
Number of Systems: 5.
Source: GAO analysis of EPA data.
[End of figure]
EPA and U.S. Geological Survey officials and other researchers told us
that technology is now available to detect perchlorate at levels below
1 part per billion, while the analytical method used under UCMR 1 had
a minimum detection level of 4 parts per billion.
Sampling conducted at various times by federal agencies, including
DOD, NASA, DOE, and EPA, has detected perchlorate in drinking water,
groundwater, surface water, soil, and sediment.[Footnote 22]
Specifically,
* DOD reported perchlorate detections at 284 of its installations, or
almost 70 percent of the 407 installations sampled from fiscal years
1997 through 2009, with detections ranging from less than 1 part per
billion to 2.6 million parts per billion. Maximum detection in parts
per billion included 30 in drinking water, 230 in sediment, 6,600 in
surface water, 786,000 in soil, and 2,600,000 in groundwater. Fifty-
three of the 284 installations, or about 20 percent, reported
perchlorate concentrations above 15 parts per billion, DOD's current
screening threshold for initiating additional site investigation when
perchlorate is detected in water. According to DOD, the agency
generally uses perchlorate in munitions and missiles, and its releases
of perchlorate occurred primarily at maintenance facilities, rocket
testing sites, and waste disposal areas.
* NASA found perchlorate at four of the seven facilities where it
sampled for the chemical from fiscal years 1997 through 2009.
According to NASA, the agency began to look for perchlorate at its
facilities across the country after a more sensitive method of
perchlorate detection became available in the late 1990s and in
response to requests from federal and state regulators. NASA reported
the highest detection of 13,300 parts per billion in groundwater in
2002 at the Jet Propulsion Laboratory in California. At the Marshall
Space Flight Center in Alabama, perchlorate detections from 2000
through 2008 fell at or below 4.4 parts per billion in groundwater.
According to NASA, at the Stennis Space Center in Mississippi, in
2003, the agency detected perchlorate concentrations ranging from 3.7
to 12,639 parts per billion in groundwater. At the White Sands Test
Facility in New Mexico, perchlorate detections from 2006 through 2009
fell at or below 2.6 parts per billion in groundwater. At the Jet
Propulsion Laboratory, NASA attributed perchlorate contamination to
the disposal of perchlorate waste in underground pits during the 1940s
and 1950s. According to NASA, perchlorate contamination at Stennis is
associated with munitions testing.
* DOE detected perchlorate at the five facilities where it sampled for
the chemical in fiscal years 1998 through 2009--Lawrence Livermore
National Laboratory Site 300 in California, Los Alamos National
Laboratory in New Mexico, the Pantex Plant in Texas, Sandia National
Laboratories in New Mexico, and the Energy Technology Engineering
Center at the Santa Susana Field Laboratory in California.[Footnote
23] Detections occurred in groundwater or soil and ranged from less
than 1 part per billon to 3,090 parts per billion. DOE reported the
highest concentrations (3,090 parts per billion) in perched
groundwater at the Pantex Plant.[Footnote 24] According to DOE,
perchlorate contamination resulted from historical waste management
practices and testing of high explosives.
* As of June 2010, EPA reported perchlorate detections at 40 sites on
the National Priorities List. In addition to 25 sites maintained by
DOD, NASA, DOE, and the U.S. Department of the Interior, there were 15
private sites. At private sites, the highest perchlorate levels ranged
from 13 to 682,000 parts per billion in groundwater. See appendix II
for a list of National Priorities List sites where perchlorate has
been identified as a contaminant of concern.
* Overall, considering detections reported by EPA and DOD, as shown in
figure 2, perchlorate has been detected in 45 states, the District of
Columbia, and three U.S. territories.
Figure 2: Maximum Perchlorate Concentrations Reported in Any Media as
of October 2009:
[Refer to PDF for image: illustrated U.S. map]
Maximum concentration reported:
No perchlorate reported:
Kentucky:
Maine:
Montana:
New Hampshire:
Vermont:
Less than 4 parts per billion:
Guam:
Hawaii:
North Dakota:
Puerto Rico:
Rhode Island:
Wisconsin:
4 to less than 100 parts per billion:
Alaska:
Connecticut:
Georgia:
Idaho:
Louisiana:
Michigan:
Minnesota:
Mississippi:
Nebraska:
Northern Mariana Islands:
Ohio:
Pennsylvania:
South Carolina:
South Dakota:
Wyoming:
100 to less than 1,000 parts per billion:
Colorado:
District of Columbia:
Florida:
Indiana:
Iowa:
New Jersey:
North Carolina:
Washington:
1,000 to less than 5,000 parts per billion:
Illinois:
New York:
Tennessee:
Virginia:
5,000 to less than 100,000 parts per billion:
Kansas:
New Mexico:
Oklahoma:
100,000 to less than 500,000 parts per billion:
Delaware:
Maryland:
Massachusetts:
Missouri:
Oregon:
500,000 or more parts per billion:
Alabama:
Arkansas:
Arizona:
California:
Nevada:
Texas:
Utah:
West Virginia:
Sources: EPA and DOD; Map Resources (map).
[End of figure]
Two states, California and Massachusetts, mandate that public water
systems sample for perchlorate to ensure that public drinking water
supplies in their states comply with state drinking water standards (6
parts per billion in California and 2 parts per billion in
Massachusetts). Although initial testing of drinking water systems
found some levels of perchlorate contamination, testing undertaken in
fiscal year 2009 found no drinking water systems that violated the
standard in either state, according to state officials. In California,
according to state officials, they also track perchlorate in
groundwater because 40 percent of the state's drinking water supply
comes from groundwater. California officials told us that perchlorate
occurrence is widespread in the state, with Southern California having
more detections at higher levels in groundwater than other parts of
the state. According to California officials, this perchlorate came
from a variety of sources including defense activities and Chilean
fertilizer. In Massachusetts, perchlorate levels at or above 2 parts
per billion have been found in only a few locations in groundwater and
in one surface water supply, according to state officials. However,
many other groundwater supplies have detected perchlorate at levels
that are less than 2 parts per billion.
Additionally, research conducted in Arizona and northwest Texas
detected relatively low levels of perchlorate. In a 2004 report, the
Arizona Department of Environmental Quality, among others, assessed
the extent of perchlorate occurrence in the state's water sources,
including the Colorado River, which is known to be contaminated with
perchlorate from a chemical plant near Henderson, Nevada.[Footnote 25]
The study found that, while perchlorate is present in certain areas of
the state, the concentrations in bodies of water not associated with
industrial sites were generally at levels well below 14 parts per
billion, which was Arizona's health-based guidance level for
perchlorate at the time.[Footnote 26] Also in 2004, Texas Tech
University reported on the source and distribution of perchlorate in
northwest Texas groundwater.[Footnote 27] The study found widespread
perchlorate occurrences at very low concentrations and concluded that
they were likely the result of natural processes and not caused by
human activities.
From 2005 to 2007, the U.S. Geological Survey published several
studies in collaboration with other researchers investigating
naturally occurring perchlorate in groundwater, surface water, and
soils in the United States.[Footnote 28] In addition, a 2009 U.S.
Geological Survey study found perchlorate from Chilean fertilizer in
Long Island, New York, and concluded that other areas in the United
States that used Chilean fertilizer in the late nineteenth century
through the twentieth century may also contain perchlorate.[Footnote
29] In addition to the key studies cited above, smaller-scale studies
have also been conducted.
Food and Drug Administration and Other Researchers Have Found
Perchlorate in a Variety of Foods at Low Concentrations:
In addition to finding perchlorate in water and soil, Food and Drug
Administration (FDA) and other researchers have found perchlorate in a
variety of foods. Existing research suggests several ways that
perchlorate may enter the food supply, such as the use of perchlorate
contaminated water in agriculture. The most comprehensive study of
perchlorate in food--FDA's 2006 Total Diet Study[Footnote 30]--found
perchlorate in 74 percent of the 285 food items tested across the
country.[Footnote 31] These food items represent the major components
of the American diet, such as dairy, meat, fruits, and vegetables.
Certain foods, such as tomatoes and spinach, had higher perchlorate
levels than others. Using the analytical results for the food samples
collected, FDA researchers calculated and reported the estimated
average perchlorate intake from food for the total U.S. population and
14 age and gender subgroups.[Footnote 32] Estimated average
perchlorate intake from each food item varied by age and gender, but
the average total consumption of perchlorate for all groups was below
the 2005 NRC-recommended reference dose for perchlorate exposure of
0.0007 milligrams per kilogram of body weight per day. The highest
level of average perchlorate consumption was reported for children 2
years of age, with an estimated consumption ranging from 0.00035 to
0.00039 milligrams per kilogram of body weight per day. According to
the study, the average level of perchlorate consumption for these
children was higher because they consume more food per their body
weight, and they have different food consumption patterns--with over
half of their perchlorate intake coming from dairy foods. According to
an FDA official, in 2008, FDA conducted another round of Total Diet
Study sampling and is in the process of compiling the data, though the
FDA official we spoke with does not expect results to be published
until later in 2010 or 2011.
Other studies and researchers have found that certain foods are more
likely than others to contain perchlorate. For example, a 2009 study
by researchers at the Centers for Disease Control and Prevention found
perchlorate in all types of powdered infant formula, with higher
concentrations in milk-based formula.[Footnote 33] Similarly, a 2008
study on foods produced in the lower Colorado River region reported
perchlorate in milk and various fruits and vegetables, including
lettuce, but researchers concluded that few individuals would be
exposed to perchlorate levels exceeding EPA's reference dose.[Footnote
34] According to researchers we contacted, only one study has
attempted to quantify the contribution of various sources of
perchlorate to the food supply. A 2006 study concluded that Chilean
fertilizer and man-made perchlorate are the main and comparable
contributors to the perchlorate found in the food supply, while
naturally occurring perchlorate is a lesser source.[Footnote 35]
Finally, researchers we spoke with said that more studies are needed
to better understand the extent to which perchlorate exists in the
food supply.
While the Likely Sources of Some Perchlorate Detections Are Known,
Sources of Others Can Be Difficult to Determine:
According to the perchlorate researchers we spoke with, concentrations
of perchlorate at or above 100 parts per billion are generally the
result of activities involving man-made perchlorate, such as the use
of perchlorate in manufacturing or as a solid rocket propellant.
Researchers we contacted told us that perchlorate detected at levels
above 100 parts per billion is generally man-made and is limited to a
specific area. Further, EPA, DOD, California, and Massachusetts
officials told us they have generally been able to determine the
likely sources of localized high concentrations of perchlorate, such
as those detected at certain Superfund sites.
Concentrations of perchlorate below 100 parts per billion can result
from the use of man-made perchlorate, natural processes, or the use of
fertilizer containing naturally occurring perchlorate. Researchers we
spoke with said that naturally occurring perchlorate formed
atmospherically is typically found in water or soil at 1 part per
billion or less, while perchlorate found in water or soil due to
Chilean fertilizer can vary in concentration ranges but generally is
not found at levels greater than 30 parts per billion. Levels of
perchlorate below 100 parts per billion can also be attributed to
various activities, including localized uses, such as fireworks and
road flares, which release perchlorate that is typically diluted over
a short time period, researchers said.[Footnote 36]
The sources of concentrations of perchlorate below 100 parts per
billion found around the country are often difficult to determine when
there are no records of historic use or when there is more than one
potential source. According to researchers we spoke with, current
technology can often differentiate between man-made and naturally
occurring perchlorate, but it cannot yet differentiate among different
sources of man-made perchlorate. DOD has funded the development of
this technology, which identifies the isotopic signature or
fingerprint of a perchlorate sample and compares the signature with
known sources of perchlorate.[Footnote 37] According to researchers we
contacted, because man-made perchlorate and naturally occurring
perchlorate have different isotopic signatures, researchers can
distinguish between them. However, the technology is not widely used
to identify sources of perchlorate because it is expensive, and there
is no EPA- or state-certified identification method available.
Therefore, federal and state officials told us that they rely mainly
on historical records to identify sources of perchlorate. For example,
officials identify sites where they believe perchlorate was used and
gather site-specific documentation to ascertain perchlorate sources.
In the case of CERCLA sites, EPA officials said that they do not focus
on identifying perchlorate sources. Rather, they attempt to identify
the potentially responsible party for responding to the contamination,
such as current or former owners and operators of a site. CERCLA
explicitly identifies four types of parties that can be held
responsible, including (1) owners or operators of a site; (2) former
owners or operators of the site at the time hazardous substances were
disposed of; (3) those who arranged for disposal or treatment of
hazardous substances (often called generators); and (4) transporters
of hazardous waste.[Footnote 38] According to EPA, the agency
identifies responsible parties by, among other actions, reviewing
documentation related to the site; conducting interviews with
government officials or other knowledgeable parties; performing
historical research on the site, such as searching for previous owners
of the property; sampling soil or groundwater at the site; and
requesting additional information from relevant parties.
DOD, NASA, and DOE Have Sampled for Perchlorate, Begun Cleanup Actions
at Some Sites, and Taken Steps to Lessen Releases:
DOD, NASA, and DOE have sampled for perchlorate at a number of their
facilities and have begun cleanup actions at some sites. According to
DOD, DOE, and NASA officials, by complying with current federal and
state waste disposal laws and regulations, they have lessened
perchlorate releases. Further, DOD and DOE have taken additional
actions to lessen perchlorate releases such as DOD's development of
perchlorate substitutes.
DOD, NASA, and DOE Have Sampled for and, at Some Sites, Cleaned Up
Perchlorate:
DOD officials told us that the military services are to sample for
perchlorate at their installations wherever there is a release or
suspected release and follow the same CERCLA procedures as for other
contaminants. In general, to determine whether to sample for
perchlorate at an installation, DOD installations rely on historical
records and knowledge of perchlorate use, DOD officials said.
According to our analysis of DOD data from fiscal year 1997 through
fiscal year 2009, DOD sampled for perchlorate at 407 installations. Of
the 361 installations that reported not sampling, the primary reason
cited for not sampling was that there was no history, record, or
indication of perchlorate use, according to our analysis of DOD data.
In addition, beginning in 2005, DOD began requiring the military
services to identify and evaluate the extent to which the use of
military munitions on operational ranges has resulted in the potential
for munitions constituents, including perchlorate, to migrate off-
range and create unacceptable risk to human health and the
environment.[Footnote 39] In 2004, DOD collaborated with the state of
California and finalized a procedure for prioritizing perchlorate
sampling at DOD facilities in California, known as the California
Prioritization Protocol.[Footnote 40] Through this procedure, DOD and
California screened 924 DOD sites that had the potential for
perchlorate releases and concluded that the majority of potential
perchlorate releases associated with DOD sites had already been
identified through existing environmental programs and were being
addressed.[Footnote 41] Additionally, DOD and California officials
agreed that, based on the results of the prioritization, the current
regulatory standards for perchlorate, sampling results to date, as
well as actions taken by DOD to manage new releases and remediate
known perchlorate releases, it appears that DOD's installations and
formerly used defense sites are not significantly impacting California
public drinking water wells.[Footnote 42]
According to DOD's current perchlorate policy, when detections in
water equal or exceed an identified threshold level--currently EPA's
health advisory level of 15 parts per billion or a stricter state
standard if identified by DOD--DOD is to conduct further
investigations to determine whether additional action is warranted.
[Footnote 43] Decisions as to whether to take further action are
generally made at the military service's installation level. According
to Army, Air Force, and Navy officials, the actions taken at
installations may include conducting additional sampling, identifying
the contaminated media, characterizing the extent of contamination,
and adding perchlorate to the installation's list of contaminants of
concern.[Footnote 44]
Our analysis of data from DOD's perchlorate database showed that
military service officials had decided to take action beyond initial
sampling at 48 of the 53 installations with perchlorate detections
above 15 parts per billion. (See app. III.) Redstone Arsenal in
Alabama and Edwards Air Force Base in California illustrate some of
the actions taken by the Army and the Air Force beyond sampling to
address perchlorate.
* Redstone Arsenal. In 2000, the Army found perchlorate in groundwater
and soil at sites associated with rocket motor production. Between
2005 and 2009, the Army conducted an investigation of groundwater to
characterize the nature of the contamination and examined potential
treatment options, including ion exchange.[Footnote 45] According to
DOD officials, the Army has identified and planned a number of actions
to remove contaminated soils that serve as an on-going source of
perchlorate to groundwater. The Army is drafting a memorandum of
understanding with the city of Huntsville whereby the city will
consult with the Army before approving any well installation requests
for areas with the potential for perchlorate contamination. However,
according to EPA officials, because DOD has not signed an interagency
agreement for Redstone, EPA has no legal mechanism to ensure that the
Army formally coordinates with adjacent government entities to limit
exposure to off-site wells that may be contaminated.[Footnote 46]
Finally, according to DOD officials, the Army is in the process of
obtaining regulatory approval from EPA for further site investigation
on some perchlorate contaminated areas, which could determine the need
for and feasibility of remedial action.
* Edwards Air Force Base. In 1997 and 1998, the Air Force found
perchlorate in groundwater at two locations associated with solid
rocket propellant testing, including the North Base and the Air Force
Research Laboratory. The Air Force attributes contamination at North
Base to past NASA Jet Propulsion Laboratory activities at the site.
However, as site owner, the Air Force has taken responsibility for
responding to the release. According to Air Force officials, at North
Base, the groundwater plume has stayed on the base and has not
contaminated drinking water supplies. In 2003, the Air Force began
operating an ion exchange system to treat perchlorate in groundwater.
By 2009, the Air Force had reduced the level detected from 30,700 to
3,700 parts per billion. The Air Force also removed 50 pounds of
perchlorate from the soil and reduced the level detected from 110,000
to 300 parts per billion in 2007. At the Air Force Research Laboratory
sites, according to Air Force officials, the Air Force found it
impractical to take remedial action because the perchlorate-
contaminated groundwater was trapped in bedrock from 20 to over 200
feet below the earth's surface and would be extremely costly to
remove. Furthermore, according to Air Force officials, it would take
over 1,000 years to remediate perchlorate at the sites. EPA officials
we spoke with agreed that no solution existed to clean up this
perchlorate. According to Air Force officials, EPA and state
regulators have agreed with the Air Force's decision not to clean up
the sites. In addition, to treat perchlorate in soil, the Air Force
has removed 10 cubic yards of contaminated soil and rock at one
research laboratory site and has contracted for the removal of an
additional 40 cubic yards of contaminated soil.
EPA and state regulatory officials told us that the actions DOD takes
to respond to perchlorate contamination vary, depending on the
military service, installation, and personnel involved. For example,
EPA officials told us that staff at Edwards Air Force Base proactively
took steps to address perchlorate contamination at the base. According
to Air Force officials, personnel at Edwards began investigating
perchlorate occurrence in 1997. At the time, DOD had no perchlorate
policy. In addition, according to EPA officials, DOD had not approved
funding to treat perchlorate at Edwards, so personnel at Edwards
convinced DOD to fund research on perchlorate treatment technologies
at Edwards that were eventually used to remediate perchlorate at the
base. In contrast, according to a New Mexico state official, for
several years, the Air Force had not taken steps to remediate
perchlorate at Kirtland Air Force Base despite requirements to do so
under state law implementing RCRA. According to DOD officials, there
is disagreement over whether further actions at Kirtland should be
conducted under CERCLA pursuant to DOD's perchlorate policy or under
the state's RCRA authority. According to state and DOD officials, the
Air Force submitted a site investigation work plan in 2010 to address
perchlorate releases, and Air Force officials told us that they have
begun investigating the site.
In addition to sampling for and, in some cases, cleaning up
perchlorate, DOD has provided funding for research and development of
perchlorate treatment technologies.[Footnote 47] This work, among
other things, is funded mainly through two programs--the Strategic
Environmental Research and Development Program and the Environmental
Security Technology Certification Program.[Footnote 48] From fiscal
years 1998 through 2009, DOD spent at least $84 million researching
and developing perchlorate treatment technologies, according to a DOD
official. According to DOD, the development and use of innovative
environmental technologies support the long-term sustainability of
DOD's training and testing ranges, as well as significantly reduce
current and future environmental liabilities. The programs help DOD
identify better ways to treat contaminants, including perchlorate, a
DOD official said. For example, several DOD installations with
perchlorate detections obtained funds for pilot treatment projects
from DOD and used the systems they developed to clean up perchlorate.
According to NASA officials, the agency has detected perchlorate at
four of the seven facilities where sampling occurred based on the
historical use of perchlorate. NASA has undertaken a major perchlorate
cleanup effort at one facility--the Jet Propulsion Laboratory in
Pasadena, California, where NASA detected a groundwater plume that had
contaminated local drinking water supplies. To respond to the release,
NASA took several actions. To clean up perchlorate in groundwater at
the Jet Propulsion Laboratory, NASA installed a biological fluidized
bed reactor--a system that uses bacteria to treat perchlorate. To
clean up perchlorate in groundwater in Altadena, California, a
neighboring community, NASA installed an ion exchange system, which
began operating in 2004. In addition, NASA is currently working with
the city of Pasadena to construct a groundwater treatment system.
According to NASA officials, all the groundwater treatment systems
will need to operate for at least 18 years to clean up the perchlorate
plume and, as of 2009, the systems had been operational for 5 years.
As of 2010, perchlorate groundwater detections are about 150 parts per
billion in the source area of contamination, compared with 13,300
parts per billion detected in 2002, according to NASA officials.
NASA is monitoring perchlorate at the other three facilities where it
has found perchlorate in groundwater--the Marshall Space Flight Center
in Alabama, the Stennis Space Center in Mississippi, and the White
Sands Test Facility in New Mexico. From 2003 to 2008, perchlorate
detections at Marshall ranged up to 4.4 parts per billion at the
monitoring well with the highest detections. NASA is determining what
actions may be needed at Stennis, where perchlorate detections ranged
up to 40,700 parts per billion at the monitoring well with the highest
detections in 2005. According to NASA officials, perchlorate
contamination at Stennis is associated with past DOD activities, such
as munitions tests conducted more than 30 years ago. Both NASA and DOD
officials told us that they are currently discussing the agency
responsibilities for responding to perchlorate releases. According to
a NASA official, the agency is monitoring perchlorate at White Sands
as directed by the state of New Mexico and generally detections fall
below 1 part per billion. In addition to monitoring at Marshall,
Stennis, and White Sands, NASA officials said, for the past 25 years,
the agency has conducted environmental monitoring after space launches
at the Kennedy Space Center in Florida, but it has detected no
perchlorate.
Finally, according to DOE officials, the agency has sampled and
detected perchlorate at all five facilities where there was a
potential for contamination based on the use of the chemical in high
explosives research, development, and testing. DOE has taken a variety
of actions at these five facilities.
* At the Pantex Plant in Texas, in 1999, DOE detected perchlorate at
408 parts per billion in perched groundwater that sits above the
regional drinking water aquifer[Footnote 49] and, in 2007, after
installing additional monitoring wells, the agency detected
perchlorate in the perched groundwater at concentrations up to 1,070
parts per billion, DOE officials said. In June 2009, DOE detected
perchlorate as high as 3,090 parts per billion in the perched
groundwater, DOE officials told us.[Footnote 50] With the approval of
EPA and the state of Texas, DOE is using bioremediation to clean up
perchlorate in the perched groundwater to 26 parts per billion and has
put restrictions in place to prevent the use of perched groundwater
without treatment.
* At Lawrence Livermore National Laboratory Site 300 in California,
DOE first detected perchlorate in groundwater in 1998. The highest
historical detection was 92 parts per billion in 2008. DOE agreed with
EPA and the state of California in 2008 to clean up perchlorate to 6
parts per billion, the state's drinking water standard. DOE is
treating perchlorate using ion exchange and had reduced the highest
level detected to 69 parts per billion in 2009, according to agency
officials. Further, DOE is planning to study whether bioremediation
can also be used to clean up the perchlorate-contaminated groundwater.
* At Los Alamos National Laboratory in New Mexico, DOE detected
perchlorate in groundwater wells in the late 1990s. According to DOE
officials, in general, current perchlorate concentrations in
groundwater are less than 10 parts per billion, but detections range
from 80 to 130 parts per billion in a group of deep wells that monitor
a perched groundwater zone above the water supply aquifer. DOE is
continuing to monitor the levels of perchlorate in groundwater,
according to agency officials.
* At Sandia National Laboratories, also in New Mexico, between 2000
and 2009, DOE sampled for perchlorate in groundwater. Detections were
at levels less than 15 parts per billion except in one well, where the
highest detection in 2006 was 1,260 parts per billion. However,
according to DOE officials, the Air Force sampled the well recently
and detected perchlorate at only 2.7 parts per billion.[Footnote 51]
In 2001, DOE detected perchlorate in soil ranging from 16.7 to 1,040
parts per billion. According to DOE officials, the state of New Mexico
is currently requiring DOE to continue to monitor the levels of
perchlorate in groundwater at Sandia and evaluate the need for further
action.
* At the Energy Technology Engineering Center at the Santa Susanna
Field Laboratory in California, in 2000, DOE detected perchlorate in
groundwater at 18 parts per billion, in soil at 3,600 parts per
billion, and in sediment at 6 parts per billion, DOE officials said.
According to DOE officials, the agency is planning additional sampling
at new sites.
Improved Waste Disposal Practices and Research May Lessen Perchlorate
Releases:
DOD, DOE, and NASA officials we contacted agreed that perchlorate
contamination at their facilities was generally caused by waste
disposal practices that were commonly used before the enactment of key
environmental laws, such as RCRA. Historically, these practices
included, among others, disposing of perchlorate waste in open pits,
open burning and detonation of perchlorate, and using water to remove
perchlorate residue from rocket engines, which contributed to
contamination in groundwater. DOD, DOE, and NASA officials told us
that their current practices for perchlorate use and disposal follow
current federal and state environmental laws and regulations and, by
doing so, lessen perchlorate releases. For example, DOD officials told
us that whereas historically certain munitions were burned or
detonated in open sites, they are now handled in contained areas and
burned on steel pads subject to requirements for the management and
disposal of the waste. Furthermore, according to Air Force officials,
perchlorate is now removed using a dry process that seals the
perchlorate before it is burned rather than a wet process that allowed
it to contact the ground and potentially contaminate groundwater. In
addition, at DOE's Lawrence Livermore National Lab Site 300, to reduce
the amount of contaminants in general, including ammonium perchlorate,
all but one of the outside firing tables--areas outside the laboratory
used to test high explosives--that could release contaminants to the
environment have been closed, according to DOE officials. According to
NASA officials, NASA believes that there is no contamination caused by
current perchlorate use during space shuttle launches, because rapid
combustion consumes virtually all of the perchlorate during the first
two minutes of flight and sampling around rocket launch complexes,
such as the Kennedy Space Flight Center, has detected no perchlorate.
In addition to lessening perchlorate releases, from fiscal years 1999
through 2009, DOD spent at least $26 million developing perchlorate
substitutes, according to a DOD official.[Footnote 52] For example, in
1999, DOD's Army Research, Development and Engineering Command began
developing perchlorate substitutes for use in weapons simulators,
flares, and rockets, according to DOD officials. Regarding weapons
simulators, DOD researchers have developed perchlorate substitutes for
training simulator hand grenades and artillery shells for use on Army
training ranges, and DOD officials estimated that production of these
simulators will begin in early 2011. DOD officials estimated that the
use of the new weapons simulators should reduce potential perchlorate
use on Army training ranges by 35 to 70 percent. Additionally, DOD is
conducting research on ways to recycle perchlorate removed from
discontinued military munitions.
In the Absence of a Federal Standard, Some States Have Set Drinking
Water Standards and Guidance Levels for Perchlorate:
In the absence of a federal regulatory standard for perchlorate in
drinking water, California and Massachusetts have adopted their own
standards. In addition, at least 10 other states have established
guidance levels for perchlorate in various media.
California's and Massachusetts' Actions to Set Regulatory Standards
for Perchlorate and Information on the Associated Benefits and Costs:
California and Massachusetts have taken a variety of actions leading
to establishing state regulatory standards for perchlorate. California
promulgated its drinking water standard for perchlorate of 6 parts per
billion in 2007, and Massachusetts set a drinking water standard of 2
parts per billion in 2006. Each state has also identified some of the
benefits and costs of setting these standards.
California's Actions:
California first identified perchlorate as an unregulated contaminant
requiring monitoring in January 1997 after the chemical was found in
drinking water wells near Aerojet, a rocket manufacturer in Sacramento
County that had used ammonium perchlorate as a solid rocket
propellant. Subsequent monitoring that year by the California
Department of Public Health[Footnote 53] found perchlorate in dozens
of drinking water wells near Aerojet and in southern California,
principally in the counties of Los Angeles, Riverside, and San
Bernardino. State level testing also found perchlorate in Colorado
River water, an important source of drinking water and agricultural
irrigation water for southern California.
In 1997, in response to the detections of perchlorate in drinking
water, the California Department of Public Health set an action level
[Footnote 54] of 18 parts per billion based on the high end of EPA's
1995 provisional reference dose range, which had a drinking water
equivalent of 4 to 18 parts per billion. In 1999, the department added
perchlorate to the list of unregulated contaminants that public water
systems were required to monitor. In January 2002, when EPA released a
revised draft reference dose for perchlorate that corresponded to 1
part per billion in drinking water, the California Department of
Public Health lowered its action level to 4 parts per billion, the
lower end of EPA's 1995 provisional reference dose range of values,
and the lowest level that the analytical method in use at the time
could reliably measure.[Footnote 55] Also in 2002, California enacted
a law requiring the Office of Environmental Health Hazard Assessment
(OEHHA) to establish a public health goal and the Department of Public
Health to establish a state drinking water standard for perchlorate.
Under state law, before the Department of Public Health establishes a
standard, OEHHA must assess the contaminant's risks to public health.
OEHHA's risk assessment is required to contain "an estimate of the
level of the contaminant in drinking water that is not anticipated to
cause or contribute to adverse health effects, or that does not pose
any significant risk to health."[Footnote 56] This level is called a
public health goal. To calculate the public health goal, OEHHA used
data from the 2002 Greer study on the effects of perchlorate on
healthy adults,[Footnote 57] the same study used by the NRC in its
2005 report, applied an uncertainty factor of 10 to protect pregnant
women and infants, and assumed that 60 percent of perchlorate exposure
comes from water to arrive at a proposed public health goal of 6 parts
per billion. According to OEHHA, the draft public health goal for
perchlorate was more extensively reviewed than any of the other public
health goals that OEHHA has developed. The draft technical support
document for the proposed public health goal was reviewed twice by
University of California scientists.[Footnote 58] EPA also peer
reviewed the document. In addition, OEHHA held two public comment
periods and a public workshop on the draft document. In March 2004,
OEHHA established a public health goal for perchlorate in drinking
water of 6 parts per billion. In its technical support document, OEHHA
made a commitment to review the NRC report assessing the potential
adverse health effects of perchlorate upon its completion and, if
necessary, revise the public health goal. When NRC released its report
in January 2005,[Footnote 59] OEHHA reviewed the report and determined
that the findings were consistent with and supported the approach that
OEHHA used to develop its public health goal.
By law, the California Department of Public Health is required to set
a drinking water standard as close to the public health goal as is
economically and technologically feasible. To determine whether the
standard for perchlorate should be proposed at the public health goal
level of 6 parts per billion, the Department of Public Health
evaluated the feasibility of standards at different levels in terms of
available analytical methods for detecting perchlorate, monitoring
costs, available treatment technologies for removal to the proposed
maximum contaminant level, and the estimated fiscal impact on
California drinking water utilities to comply with the proposed
standard. The department estimated that the total annual costs to
public water systems of a drinking water standard at 6 parts per
billion would be about $23.9 million a year and that the total
population avoiding exposure would be 518,600, whereas the total
annual cost at 10 parts per billion would be an estimated $8.7 million
with about 188,360 people avoiding exposure. The department noted that
while the cost impacts of a standard above 10 parts per billion would
be minimal, very little public health benefit would be achieved. To
further evaluate the feasibility, the department estimated that the
annual costs for larger systems that exceeded the drinking water
standard would be $18 per customer, while annual costs for smaller
systems would be $300 to $1,580 per customer. Because of this
difference, the department proposed to provide variances for smaller
systems based on affordability criteria. Based on that analysis, the
department promulgated a regulatory drinking water standard for
perchlorate of 6 parts per billion, which became effective in October
2007. Now that a standard has been established, California public
drinking water systems must monitor to ensure that the drinking water
they distribute complies with this standard. Should a system exceed
the standard, it must notify the Department of Public Health and the
public and take steps to immediately come back into compliance.
Systems in noncompliance may face fines or permit suspension or
revocation, among other possible enforcement measures. California
Department of Health officials told us that public water systems that
exceed the standard generally treat the contaminated water or turn off
the contaminated well.
In addition to setting a regulatory standard for drinking water,
California adopted best management practice regulations for handling
materials, products, and waste that contain perchlorate. For example,
those who manufacture, package, distribute, receive, or generate
certain materials containing perchlorate must ensure they are properly
contained in water-resistant packaging and labeled, and nonhazardous
perchlorate waste[Footnote 60] must be disposed of in a hazardous
waste landfill or a composite-lined portion of a nonhazardous
landfill.[Footnote 61] These regulations, which were adopted in
December 2005, and became effective in July 2006, apply to any person
or business that manages--such as by using, processing, generating,
transporting, storing, or disposing--perchlorate materials or waste,
with certain exceptions.[Footnote 62]
Massachusetts' Actions:
In 2001, perchlorate was detected in groundwater at the Massachusetts
Military Reservation at 600 parts per billion and, in 2002, in
monitoring wells upstream from drinking water wells in the adjacent
town of Bourne at concentrations less than 1 part per billion. The
Bourne Water District shut three municipal wells when perchlorate was
detected at levels less than 1 part per billion and, in March 2002
formally requested guidance from the Massachusetts Department of
Environmental Protection on the health significance of perchlorate in
drinking water. Based on a review of available information on the
toxicity of perchlorate, including EPA's 2002 draft health assessment
for perchlorate and draft reference dose with a drinking water limit
equivalent to 1 part per billion, the department recommended that the
water district notify sensitive subgroups, such as pregnant women,
should perchlorate concentrations exceed 1 part per billion and advise
them to avoid consuming the water.
In 2003, the Massachusetts Department of Environmental Protection
convened an external science advisory committee to evaluate the peer-
reviewed studies on perchlorate. Given the limited number of such
studies on perchlorate and its effect on sensitive populations, in
February 2004, the department established a drinking water health
advisory level for perchlorate of 1 part per billion consistent with
EPA's January 2002 draft perchlorate health assessment. According to
state environmental officials, Massachusetts adopted an advisory level
at 1 part per billion to protect sensitive populations, specifically,
pregnant women and their fetuses, infants, children up to 12 years of
age, and people with thyroid conditions. In March 2004, Massachusetts
initiated the process for setting a drinking water standard by issuing
emergency regulations requiring most public water supply systems to
test for perchlorate. Perchlorate was found in 9 of 600 systems
tested, with perchlorate detections ranging from just below 1 part per
billion to 1,300 parts per billion.[Footnote 63] Next, to assess the
health risks of perchlorate exposure, department toxicologists and an
external science advisory committee reviewed scientific studies,
including the 2005 NRC perchlorate study,[Footnote 64] as well as
other information that had recently become available, such as a 2005
study on perchlorate in breast milk[Footnote 65] and data made
available by FDA on perchlorate in food.[Footnote 66] To calculate a
reference dose for perchlorate, Massachusetts used the lowest-observed-
adverse-effect level[Footnote 67] from the Greer study[Footnote 68] as
the point of departure. Given the limited sample size of the study
(i.e., 37 subjects), Massachusetts used a larger uncertainty factor
(100) than applied by the NRC (10) to be more protective of infants
and pregnant women and their fetuses, and to allow for data gaps. The
department also assumed a 20 percent exposure from drinking water to
take into account the various other potential sources and exposure
pathways of perchlorate (i.e., food), especially for infants and
pregnant women, which resulted in a reference dose for perchlorate
with a drinking water equivalent level less than 1 part per billion.
To arrive at a drinking water standard, the department considered
information on the availability and feasibility of testing and
treatment technologies, as well as data that demonstrated that
perchlorate can enter drinking water as a by-product of hypochlorite
(e.g., bleach) solutions used as disinfectants in water treatment
plants. The department chose to set the standard at a level that does
not create any disincentive for public water systems to disinfect
their water supplies. The department determined that a maximum
contaminant level of 2 parts per billion would provide the best
overall protection of public health, considering the benefits of
disinfection, while retaining a margin of safety to account for
uncertainties in the available data. In July 2006, Massachusetts
became the first state to set a drinking water standard for
perchlorate. At the same time, Massachusetts set cleanup standards for
perchlorate, including a 2 parts per billion cleanup standard for
groundwater that could be classified for drinking water.
In addition to setting a regulatory standard for perchlorate,
Massachusetts has also taken action to minimize potential problems
associated with perchlorate by issuing best management practices
guidance for blasting operations and for fireworks displays. Also,
Massachusetts officials reported that they are working with EPA to
develop guidance for the use of hypochlorite solutions in water
treatment plants.
Information on the Benefits and Costs of Setting a Regulatory Standard
for Perchlorate in California and Massachusetts:
While California and Massachusetts estimated the costs and benefits of
setting standards for perchlorate as part of their regulatory
processes, neither state has conducted a comprehensive analysis of the
actual costs and benefits of their perchlorate regulations. However,
according to California officials, setting a regulatory standard for
perchlorate has benefited public health. Massachusetts officials also
cited protecting public health, particularly children's health, as a
key benefit, and added that cleaning up water supplies can also
decrease the levels of perchlorate in food. However, while both states
estimated the benefits in terms of the reduction in the number of
people who would be exposed to perchlorate, they did not attempt to
quantify the dollar value of these benefits. In addition, officials
from both states told us that having a regulatory standard allows the
state and public water utilities to identify polluters and hold them
accountable for remediation. In particular, California officials told
us that adopting a perchlorate regulation ended DOD's reluctance to
take action in response to perchlorate releases. Massachusetts
officials reported that adopting a standard provided the impetus for
the military to conduct perchlorate cleanup. Further, Massachusetts
officials said that having a standard provides a simple and less
costly means for determining whether remediation is necessary, as well
as when no further remedial response action is necessary.
Officials from both states said that their regulatory programs had
costs to the state. While California officials acknowledged that there
were administrative costs associated with developing its drinking
water standard, they did not have data on those costs. EPA regional
officials also cited the loss of water resources when contaminated
wells were taken out of service as a cost to the state and noted that
additional costs may be incurred to clean up the water should the
state have to put some of these wells back into service because of
drought conditions. Massachusetts reported that the process used to
establish a drinking water standard cost the state approximately $1.35
million, or the equivalent of about 9 staff years. However, additional
costs for monitoring and cleanup have been minimal because the number
of public water systems with perchlorate detections above the level of
concern has been small.
Officials from both states said that their perchlorate regulation also
had costs to public water systems, including initial and ongoing
monitoring costs, capital and construction costs to install treatment
facilities, and operations and maintenance costs.
* Initial and ongoing monitoring costs. California state officials
estimated that to sample for perchlorate costs an average of $88 per
sample, while Massachusetts state officials estimated an average of
$125 per sample. The number of samples taken will vary by public water
system and whether sampling shows that the system is out of compliance
with the state's drinking water standard. While each state estimated
that monitoring costs would be higher initially because all public
systems would be required to sample for perchlorate, officials from
each state reported that most public water systems are compliant and
now only need to conduct annual monitoring.
* Capital and construction costs to install treatment facilities. In
general, determining the capital cost of a treatment facility, such as
a blending station,[Footnote 69] an ion exchange facility, or a
biological fluidized bed reactor, will depend on the individual site,
according to California officials. Some of the factors that can play a
role in the cost include the concentration of perchlorate, evidence of
other contaminants, the need to purchase additional land, and
construction costs. According to officials from each state, ion
exchange is the technology generally used for treating perchlorate in
drinking water, although California has also identified biological
fluidized bed reactors as a cost-effective technology. Ion exchange
systems have relatively low capital costs and are simpler to operate
compared with biological fluidized bed reactors, which have higher
capital costs and take up more space, according to officials at
Aerojet.
* Operations and maintenance costs. Operations and maintenance costs
will vary by type of treatment facility, water quality, and system
flow rate. California officials noted that an ion exchange system is
more expensive to operate than a fluidized bed reactor because of the
cost of replacing the resin to which perchlorate molecules adhere as
water passes through the system. When the resin becomes saturated with
perchlorate, it must be replaced and disposed of as waste. In
comparison, a fluidized bed reactor creates no waste disposal problem.
Treatment costs for an ion exchange system can run about $165 to $185
per acre foot of water, whereas treatment costs for a fluidized bed
reactor can run about $35 to $65 per acre foot, according to officials
at Aerojet. California officials told us that the high operating costs
of ion exchange can cause financial problems for small water systems.
For this reason, California allows a water system serving less than
10,000 persons to apply to the department for a variance from the
perchlorate drinking water standard if water system officials can
demonstrate that the estimated annualized cost per household for
treatment to comply exceeds 1 percent of the median household income
in the community within which the customers served by the water system
reside.
Several States Have Issued Guidance Levels for Perchlorate:
In addition to the regulatory standards set by California and
Massachusetts, at least 10 states have established for various
purposes guidance levels for perchlorate ranging from 1 part per
billion to 18 parts per billion for drinking water and from 1 part per
billion to 72 parts per billion for groundwater.[Footnote 70]
Depending on the state, a particular level may trigger public notice,
serve as a screening tool for further action, or guide cleanup action,
among other things.
Table 1 provides a listing of state guidance levels for perchlorate in
drinking water.
Table 1: Summary of State Guidance Levels for Perchlorate in Drinking
Water:
State: Arizona;
Level: 11 parts per billion;
Description: Health-based guidance level.
State: Kansas;
Level: 4 parts per billion;
Description: Drinking water threshold level used as default protective
level for all drinking water (including private wells).
State: Maryland;
Level: 1 parts per billion;
Description: Advisory level.
State: New York;
Level: 5 parts per billion;
Description: Action step triggering notification to state.
State: New York;
Level: 18 parts per billion;
Description: Action step triggering state-recommended action to reduce
concentration.
State: Texas;
Level: 4 parts per billion;
Description: Interim action level.
State: Vermont;
Level: 4 parts per billion;
Description: Guideline.
Sources: EPA and state environmental agencies.
[End of table]
Table 2 provides a listing of state guidance levels for perchlorate in
groundwater.
Table 2: Summary of State Guidance Levels for Perchlorate in
Groundwater:
State: Florida;
Level: 4 parts per billion;
Description: Cleanup target level for potable water[A].
State: Florida;
Level: 40 parts per billion;
Description: Cleanup target level for groundwater of low yield or poor
quality[A].
State: Illinois;
Level: 4.9 parts per billion;
Description: Nonregulatory health advisory used for potable water,
including potential water supplies, and as default value for
groundwater cleanup objectives.
State: Kansas;
Level: 11 parts per billion;
Description: Default risk-based cleanup level for residential or
drinking water pathway (based on established equations and current EPA
reference dose).
State: Kansas;
Level: 72 parts per billion;
Description: Default risk-based cleanup level for nonresidential
pathway (based on established equations and current EPA reference
dose).
State: Nevada;
Level: 18 parts per billion;
Description: Provisional action level used as default cleanup level
for all groundwater.
State: New Jersey;
Level: 5 parts per billion;
Description: Interim specific criterion used as default remediation
standard.
State: Texas;
Level: 17 parts per billion;
Description: Protective cleanup level for residential land use.
State: Texas;
Level: 51 parts per billion;
Description: Protective cleanup level for industrial/commercial land
use.
State: Vermont;
Level: 2 parts per billion;
Description: Interim preventive action level.
State: Vermont;
Level: 4 parts per billion;
Description: Interim enforcement standard[B].
Sources: EPA and state environmental agencies.
Note: A default value is a value used in the absence of a site-
specific risk assessment.
[A] This level, established in regulation, is not a standard but
serves as a default level for contaminated site cleanups. Alternative
levels may be used where there is sufficient site-specific information.
[B] This level is considered guidance, despite its being termed a
"standard."
[End of table]
In addition, two states--Illinois and Wisconsin--have proposed
regulatory standards for perchlorate in groundwater. Finally, New
Jersey proposed a drinking water standard of 5 parts per billion in
2009, but the state's newly appointed Commissioner of the Department
of Environmental Protection decided in March 2010 to delay adopting a
standard until EPA made its regulatory determination, and New Jersey's
proposed rule has lapsed.
Agency Comments and Our Evaluation:
We provided a draft copy of this report to DOD, DOE, EPA, and NASA for
review and comment. We received a written response from the Assistant
Deputy Under Secretary of Defense (Installations and Environment). DOD
believes that the report omitted a number of important facts and
conclusions, including the major conclusions of the California
Prioritization Protocol, the sources of perchlorate in Massachusetts,
the amount of perchlorate imported primarily for fireworks compared
with the amount of perchlorate used by DOD, information on the health
risks of perchlorate, and the conclusions of the EPA Office of
Inspector General's report regarding perchlorate health risks. We do
not agree. We believe the report contains the most important facts
relevant to our objectives. Nonetheless, in response to DOD's
comments, we did modify the report to provide some additional details
on the results of the California Prioritization Protocol. However, we
made no changes regarding the sources of perchlorate contamination in
Massachusetts because this information was already included in our
description of Massachusetts' actions to regulate perchlorate. We did
not include information on the amount of perchlorate imported into the
United States, the health risks of perchlorate, and the conclusions of
the EPA Office of Inspector General's report, because these issues
were beyond the scope of our report. For example, we were asked to
report on what is known about the likely sources of perchlorate in the
nation's water and food supply, not on the amount of perchlorate used
for different purposes. Although an organization may use a significant
amount of perchlorate for a specific purpose, the quantity used is not
necessarily indicative of the amount of perchlorate released into the
environment. Similarly, we were not asked to assess the public health
risks of perchlorate exposure, so we did not address it in this
report. Moreover, the scientific community is still debating health
risk and, as we mentioned in the report, EPA has not yet made a final
decision whether to set a regulatory standard for perchlorate in
drinking water. DOD also provided technical comments, which we
incorporated into the report as appropriate. DOD's comments and our
detailed responses are presented in appendix IV of this report.
DOE and EPA did not provide formal comments. However, they provided
technical comments by e-mail, which we incorporated as appropriate.
NASA had no comments on the report.
As agreed with your office, unless you publicly announce the contents
of this report earlier, we plan no further distribution until 30 days
from the report date. At that time, we will send copies of this report
to the appropriate congressional committees, Secretaries of Defense
and Energy, Administrators of the Environmental Protection Agency and
National Aeronautics and Space Administration, and other interested
parties. In addition, the report will be available at no charge on the
GAO Web site at [hyperlink, http://www.gao.gov].
If you or your staff members have any questions about this report,
please contact me at (202) 512-3841 or stephensonj@gao.gov. Contact
points for our Offices of Congressional Relations and Public Affairs
may be found on the last page of this report. Key contributors to this
report are listed in appendix V.
Sincerely yours,
Signed by:
John B. Stephenson:
Director, Natural Resources and Environment:
[End of section]
Appendix I: Objectives, Scope, and Methodology:
This report examines (1) what is known about the extent to which
perchlorate occurs in the nation's water and food supply and its
likely sources; (2) what actions the Department of Defense (DOD), the
National Aeronautics and Space Administration (NASA), and the
Department of Energy (DOE) have taken to respond to or lessen
perchlorate releases; and (3) the actions states, such as California
and Massachusetts, have taken to regulate perchlorate.
To determine what is known about the extent to which perchlorate
occurs in the nation's water and food supply and its likely sources,
we took a variety of actions.
* To determine what is known about the extent of perchlorate
occurrence in the nation's public drinking water systems, we obtained
and analyzed sampling data collected from 2001 through 2005 under
EPA's Unregulated Contaminant Monitoring Rule 1. We assessed the
procedure EPA used to collect the data by reviewing the statistical
design, sample selection, and quality control methods used, and
determined that the procedure was sufficiently reliable for the
purposes of this report.
* To determine what is known about the extent of perchlorate
occurrence in water and other media at DOD, NASA, and DOE
installations and facilities, we obtained data on perchlorate
occurrence at facilities owned or managed by these agencies.
Specifically, at DOD, we obtained and analyzed data from their
Perchlorate Survey Database for fiscal years 1997 through 2009. We
assessed the reliability of the data for relevant variables by
electronically testing for obvious errors in accuracy and
completeness. We also reviewed information about the data and the
systems that produced them and interviewed officials knowledgeable
about the data. When we found inconsistencies in the data, we worked
with the officials responsible for the data to clarify these
inconsistencies before conducting our analyses. We determined that the
data were sufficiently reliable for the purposes of reporting on
perchlorate sampling and detections at the installations tracked by
the database. We reviewed data provided by NASA and DOE on perchlorate
detections reported by their facilities. We also interviewed officials
from DOD, NASA, and DOE to determine that all data were reported.
* To determine what additional information existed on the extent of
perchlorate occurrence in water, we obtained data from EPA on
perchlorate occurrence at facilities on the National Priorities List--
known as Superfund sites. We also reviewed perchlorate occurrence data
provided by state environmental agencies in California, Massachusetts,
Arizona, and Texas.
* To determine what is known about the extent of perchlorate
occurrence in the nation's food supply, we performed a literature
search to identify research on perchlorate occurrence in food. We
reviewed the results of research conducted by the Food and Drug
Administration (FDA), the U.S. Department of Agriculture, the Centers
for Disease Control and Prevention, and academic researchers. We also
interviewed officials from FDA, the U.S. Department of Agriculture,
and EPA, as well as researchers at academic and private institutions,
to identify what is known about the extent of perchlorate in the food
supply, the relative source contributions, and any gaps in knowledge.
* To determine what is known about the likely sources of perchlorate,
we reviewed research literature examining the different sources of man-
made perchlorate and its uses, as well as the conditions under which
perchlorate occurs naturally. We also interviewed EPA, U.S. Geological
Survey, and state officials; researchers from a consortium of public,
private, and academic entities developing an analytical method to
determine the sources of perchlorate; and other stakeholders to obtain
information on the history of perchlorate use, as well as developments
in technology to determine the sources of known perchlorate
occurrences.
To determine the actions DOD, NASA, and DOE have taken to respond to
perchlorate releases, we reviewed and analyzed DOD data on perchlorate
occurrence from DOD's Perchlorate Survey Database, DOD state
summaries, NASA and DOE perchlorate occurrence data, EPA data on
perchlorate occurrence at facilities on the National Priorities List,
and state regulatory agency reports. We also obtained and reviewed
documentation from federal and state agencies on the actions these
three agencies have taken to respond to perchlorate releases and the
status of these actions. We also interviewed agency officials and
officials from state and other federal agencies to obtain information
and their views on (1) the actions DOD, NASA, and DOE have taken to
respond to perchlorate releases; (2) the status of these actions; and
(3) whether these actions have lessened perchlorate releases. We
visited the following DOD and NASA facilities to discuss and observe
their activities related to perchlorate cleanup: Edwards Air Force
Base (DOD), Redstone Army Arsenal (DOD), the Jet Propulsion Laboratory
(NASA), and the Marshall Space Flight Center (NASA). We selected sites
to visit that were identified by EPA, DOD, and NASA officials as
illustrative of their perchlorate response actions. To determine the
actions DOD, NASA, and DOE have taken to lessen perchlorate releases,
we reviewed documents from agency officials and discussed current
policies and practices they follow to lessen perchlorate releases. We
also visited Aerojet, a private facility that manufactures and tests
rocket engines for the space and defense industries, to discuss and
observe the operation of two types of perchlorate treatment facilities
that are also being used by federal agencies.
To determine the actions California and Massachusetts have taken to
regulate perchlorate, we reviewed state documents, such as perchlorate
occurrence reports, risk assessments, and cost benefit analyses, and
interviewed state officials. To determine the actions of other states
to regulate perchlorate, we interviewed EPA regional officials and
obtained information from the Association of State Drinking Water
Administrators and identified states that have set advisory levels and
cleanup goals for perchlorate. We interviewed environmental and public
health officials from these states and obtained and reviewed documents
related to perchlorate guidance for drinking water and groundwater.
[End of section]
Appendix II: National Priorities List Sites Where Perchlorate Has Been
Identified as a Contaminant of Concern:
State: Alabama;
Site name: Anniston Army Depot;
Site type[A]: DOD.
State: Alabama;
Site name: Redstone Arsenal (Army/NASA);
Site type[A]: DOD.
State: Arizona;
Site name: Apache Powder Company;
Site type[A]: Private.
State: Arizona;
Site name: Phoenix Goodyear Airport Area, Unidynamics;
Site type[A]: Private.
State: California;
Site name: Aerojet General Corp.;
Site type[A]: Private.
State: California;
Site name: Casmalia Resources;
Site type[A]: Private.
State: California;
Site name: Edwards Air Force Base, Air Force Research Laboratory;
Site type[A]: DOD.
State: California;
Site name: Edwards Air Force Base, Jet Propulsion Laboratory;
Site type[A]: DOD.
State: California;
Site name: El Toro Marine Corps Air Station;
Site type[A]: DOD.
State: California;
Site name: Jet Propulsion Laboratory;
Site type[A]: NASA.
State: California;
Site name: Lawrence Livermore National Laboratory Site 300;
Site type[A]: DOE.
State: California;
Site name: Mather Air Force Base (former);
Site type[A]: DOD.
State: California;
Site name: McClellan Air Force Base (former);
Site type[A]: DOD.
State: California;
Site name: San Fernando Valley, Area 2-Glendale;
Site type[A]: Private.
State: California;
Site name: San Gabriel Valley, Area 1-El Monte;
Site type[A]: Private.
State: California;
Site name: San Gabriel Valley, Area 2-Baldwin Park;
Site type[A]: Private.
State: California;
Site name: San Gabriel Valley, Area 4-Puente Valley;
Site type[A]: Private.
State: California;
Site name: Stringfellow;
Site type[A]: Private.
State: Illinois;
Site name: Sangamo Electric Dump/Crab Orchard National Wildlife Refuge;
Site type[A]: DOI.
State: Massachusetts;
Site name: Fort Devens, South Post Impact Area;
Site type[A]: DOD.
State: Massachusetts;
Site name: Massachusetts Military Reservation;
Site type[A]: DOD.
State: Maryland;
Site name: Aberdeen Proving Ground;
Site type[A]: DOD.
State: Maryland;
Site name: Naval Surface Warfare Center-Indian Head;
Site type[A]: DOD.
State: Maryland;
Site name: Ordnance Products, Inc.;
Site type[A]: Private.
State: Missouri;
Site name: Lake City Army Ammunition Plant;
Site type[A]: DOD.
State: North Carolina;
Site name: Chemtronics (aka Amcel Propulsion Inc.);
Site type[A]: Private.
State: North Carolina;
Site name: Marine Corps Air Station Cherry Point;
Site type[A]: DOD.
State: North Carolina;
Site name: Marine Corps Base Camp Lejeune;
Site type[A]: DOD.
State: Nebraska;
Site name: Nebraska Ordnance Plant (former);
Site type[A]: Private.
State: New Jersey;
Site name: Picatinny Arsenal;
Site type[A]: DOD.
State: New Jersey;
Site name: Radiation Technology, Inc.;
Site type[A]: Private.
State: New Jersey;
Site name: Shieldalloy Corp.;
Site type[A]: Private.
State: Oregon;
Site name: Portland Harbor;
Site type[A]: Private.
State: Oregon;
Site name: Umatilla Ammunition Demolition Area;
Site type[A]: DOD.
State: Tennessee;
Site name: Milan Army Ammunition Plant;
Site type[A]: DOD.
State: Texas;
Site name: Longhorn Army Ammunition Plant;
Site type[A]: DOD.
State: Texas;
Site name: Pantex Plant;
Site type[A]: DOE.
State: Utah;
Site name: Hill Air Force Base;
Site type[A]: DOD.
State: Virginia;
Site name: Naval Surface Warfare Center-Dahlgren;
Site type[A]: DOD.
State: West Virginia;
Site name: Allegheny Ballistics Laboratory, Alliant Techsystems, Inc.;
Site type[A]: DOD.
Source: EPA.
Notes: The term "site" refers to the physical location where
perchlorate was found.
According to EPA, additional National Priorities List sites may have
perchlorate at some level. However, EPA does not currently have enough
information to determine whether perchlorate is a contaminant of
concern at those sites.
[A"] Site type" includes private sites and those at federal
facilities, including the Department of Defense (DOD), the National
Aeronautics and Space Administration (NASA), the Department of Energy
(DOE), and the Department of the Interior (DOI).
[End of table]
[End of section]
Appendix III: Actions Taken by DOD at Installations with Perchlorate
Detections above 15 Parts per Billion:
State: Alabama;
Installation: Anniston Army Depot;
Service: Army;
Installation type: Active;
Media: Groundwater;
Highest detection (ppb): 31.2;
Action[A]: Ongoing monitoring.
State: Alabama;
Installation: Redstone Arsenal;
Service: Army;
Installation type: Active;
Media: Groundwater; Soil; Surface water;
Highest detection (ppb): 2,600,000(GW); 38(S); 250(SW);
Action[A]: Risk assessment under way.
State: Arkansas;
Installation: Pine Bluff Arsenal;
Service: Army;
Installation type: Active;
Media: Groundwater;
Highest detection (ppb): 500;
Action[A]: Ongoing monitoring.
State: Arizona;
Installation: Barry M. Goldwater Range;
Service: Air Force;
Installation type: Active;
Media: Soil;
Highest detection (ppb): 1,400;
Action[A]: No action needed based on consultation with regulators.
State: Arizona;
Installation: Yuma Marine Corps Air Station;
Service: Marine Corps;
Installation type: Active;
Media: Soil;
Highest detection (ppb): 786,000;
Action[A]: Ongoing monitoring.
State: California;
Installation: Beale Air Force Base;
Service: Air Force;
Installation type: Active;
Media: Groundwater;
Highest detection (ppb): 130;
Action[A]: Remediation under way.
State: California;
Installation: China Lake Naval Air Weapons Station;
Service: Navy;
Installation type: Active;
Media: Groundwater;
Highest detection (ppb): 720;
Action[A]: No action needed based on completed risk assessment.
State: California;
Installation: Edwards Air Force Base;
Service: Air Force;
Installation type: Active;
Media: Groundwater;
Highest detection (ppb): 7,700;
Action[A]: Risk assessment completed and remediation under way.
State: California;
Installation: El Centro Naval Air Facility;
Service: Navy;
Installation type: Active;
Media: Soil;
Highest detection (ppb): 43;
Action[A]: No action needed.
State: California;
Installation: El Toro Marine Corps Air Station (former);
Service: Marine Corps;
Installation type: BRAC[B];
Media: Groundwater; Soil;
Highest detection (ppb): 710 (GW); 1,600(S);
Action[A]: Risk assessment under way and bioremediation pilot study
planned.
State: California;
Installation: McClellan Air Force Base (former);
Service: Air Force;
Installation type: BRAC;
Media: Groundwater;
Highest detection (ppb): 95;
Action[A]: Risk assessment completed; Ongoing monitoring; Remediation
under way.
State: California;
Installation: Morris Dam Naval Command, Control and Ocean Surveillance
Center;
Service: Navy;
Installation type: Non-BRAC closed;
Media: Groundwater; Soil;
Highest detection (ppb): 65(GW); 754(S);
Action[A]: Risk assessment completed and remediation planned.
State: California;
Installation: San Nicolas Island Naval Outlying Field;
Service: Navy;
Installation type: Active;
Media: Soil; Surface water; Wastewater;
Highest detection (ppb): 192,570(S); 3,000(SW); 30(WW);
Action[A]: Range assessment under way.
State: California;
Installation: Seal Beach Naval Weapons Station;
Service: Navy;
Installation type: Active;
Media: Other;
Highest detection (ppb): 9,410;
Action[A]: Risk assessment under way.
State: California;
Installation: Seal Beach Naval Weapons Station-Detachment Fallbrook;
Service: Navy;
Installation type: Active;
Media: Soil;
Highest detection (ppb): 18;
Action[A]: No action needed.
State: California;
Installation: Vandenberg Air Force Base;
Service: Air Force;
Installation type: Active;
Media: Groundwater; Surface water;
Highest detection (ppb): 337(GW); 65(SW);
Action[A]: Remediation pilot study under way.
State: District of Columbia;
Installation: Spring Valley-formerly used defense site;
Service: Army;
Installation type: Non-BRAC closed;
Media: Groundwater;
Highest detection (ppb): 146;
Action[A]: Risk assessment under way; Ongoing monitoring.
State: Florida;
Installation: Eglin Air Force Base;
Service: Air Force;
Installation type: Active;
Media: Groundwater;
Highest detection (ppb): 27;
Action[A]: No action taken because munitions containing perchlorate
were removed.
State: Idaho;
Installation: Mountain Home Air Force Base;
Service: Air Force;
Installation type: Active;
Media: Soil;
Highest detection (ppb): 20;
Action[A]: Remediation complete with removal of contaminated soil and
site closure.
State: Indiana;
Installation: Crane Division, Naval Surface Warfare Center;
Service: Navy;
Installation type: Active;
Media: Groundwater; Soil; Wastewater;
Highest detection (ppb): 67(GW); 470(S); 356(WW);
Action[A]: Ongoing monitoring planned for groundwater and soil.
State: Massachusetts;
Installation: Camp Edwards/;
Massachusetts Military Reservation;
Service: Army/Air Force;
Installation type: Active;
Media: Groundwater; Soil;
Highest detection (ppb): 770(GW); 8,060(S);
Action[A]: Remediation under way.
State: Massachusetts;
Installation: Fort Devens;
Service: Army;
Installation type: Active;
Media: Groundwater;
Highest detection (ppb): 133;
Action[A]: Ongoing monitoring.
State: Maryland;
Installation: Aberdeen Proving Ground;
Service: Army;
Installation type: Active;
Media: Groundwater;
Highest detection (ppb): 140;
Action[A]: Ongoing monitoring.
State: Maryland;
Installation: Indian Head Naval Surface Facility;
Service: Navy;
Installation type: Active;
Media: Groundwater; Sediment; Soil; Surface water; Wastewater;
Highest detection (ppb): 276,000(GW); 230(Sed); 480,000(S) 190(SW);
9,500(WW);
Action[A]: Planned action for groundwater under separate program
because site is an active range; Remediation planned for sediment and
soil; Ongoing monitoring for wastewater.
State: Maryland;
Installation: White Oak Naval Surface Warfare Center (former);
Service: Navy;
Installation type: BRAC;
Media: Groundwater; Soil;
Highest detection (ppb): 880(GW); 1,400(S);
Action[A]: Remediation under way.
State: Michigan;
Installation: Camp Grayling;
Service: Army;
Installation type: Active;
Media: Groundwater;
Highest detection (ppb): 17.7;
Action[A]: Risk assessment planned.
State: Missouri;
Installation: Lake City Army Ammunition Plant;
Service: Army;
Installation type: Active;
Media: Groundwater;
Highest detection (ppb): 78;
Action[A]: Ongoing monitoring.
State: Missouri;
Installation: Whiteman Air Force Base;
Service: Air Force;
Installation type: Active;
Media: Groundwater;
Highest detection (ppb): 130;
Action[A]: Risk assessment completed;
No further action required.
State: North Carolina;
Installation: Camp Lejeune Marine Corps Base/New River Marine Corps
Air Station;
Service: Marine Corps;
Installation type: Active;
Media: Soil;
Highest detection (ppb): 350;
Action[A]: Risk assessment under way.
State: North Carolina;
Installation: Cherry Point Marine Corps Air Station;
Service: Marine Corps;
Installation type: Active;
Media: Groundwater; Soil;
Highest detection (ppb): 179(GW); 16(S);
Action[A]: Risk assessment completed; Remediation planned.
State: New Jersey;
Installation: Earle Naval Weapons Center;
Service: Navy;
Installation type: Active;
Media: Groundwater; Soil;
Highest detection (ppb): 398(GW); 87(S);
Action[A]: Ongoing monitoring.
State: New Mexico;
Installation: Cannon Air Force Base;
Service: Air Force;
Installation type: Active;
Media: Groundwater;
Highest detection (ppb): 46;
Action[A]: Ongoing monitoring.
State: New Mexico;
Installation: Fort Wingate;
Service: Army;
Installation type: BRAC;
Media: Groundwater;
Highest detection (ppb): 240;
Action[A]: Remediation planned[C].
State: New Mexico;
Installation: Holloman Air Force Base;
Service: Air Force;
Installation type: Active;
Media: Groundwater;
Highest detection (ppb): 190;
Action[A]: Risk assessment planned.
State: New Mexico;
Installation: Kirtland Air Force Base;
Service: Air Force;
Installation type: Active;
Media: Groundwater;
Highest detection (ppb): 16;
Action[A]: Risk assessment under way.
State: New Mexico;
Installation: White Sands Missile Range;
Service: Army;
Installation type: Active;
Media: Groundwater;
Highest detection (ppb): 6,700;
Action[A]: Remediation under way and pilot study.
State: Oklahoma;
Installation: McAlester Army Ammunition Plant;
Service: Army;
Installation type: Active;
Media: Groundwater;
Highest detection (ppb): 23;
Action[A]: Ongoing monitoring.
State: Oklahoma;
Installation: Tinker Air Force Base;
Service: Air Force;
Installation type: Active;
Media: Soil;
Highest detection (ppb): 5,580;
Action[A]: No action needed[C].
State: South Carolina;
Installation: Beaufort Marine Corps Air Station;
Service: Marine Corps;
Installation type: Active;
Media: Groundwater;
Highest detection (ppb): 18.2;
Action[A]: Ongoing monitoring.
State: South Carolina;
Installation: Shaw Air Force Base;
Service: Air Force;
Installation type: Active;
Media: Groundwater;
Highest detection (ppb): 27.9;
Action[A]: Ongoing monitoring Land use control.
State: South Dakota;
Installation: Rapid City Small Arms Range Annex;
Service: Army;
Installation type: Transferred;
Media: Soil;
Highest detection (ppb): 70.3;
Action[A]: Risk assessment planned.
State: Tennessee;
Installation: Arnold Air Force Base;
Service: Air Force;
Installation type: Active;
Media: Groundwater;
Highest detection (ppb): 830;
Action[A]: Risk assessment completed; Remediation pilot study under
way.
State: Tennessee;
Installation: Milan Army Ammunition Plant;
Service: Army;
Installation type: Active;
Media: Groundwater; Soil;
Highest detection (ppb): 25.4(GW); 1,400(S);
Action[A]: Risk assessment under way.
State: Texas;
Installation: Camp Bullis;
Service: Army;
Installation type: Active;
Media: Groundwater;
Highest detection (ppb): 174;
Action[A]: Risk assessment under way; Ongoing monitoring.
State: Texas;
Installation: Longhorn Army Ammunition Plant;
Service: Army;
Installation type: Transferred;
Media: Groundwater; Other; Sediment; Soil; Surface water;
Highest detection (ppb): 360,000(GW); 23,000(O); 172(Sed); 572,000(S);
122(SW);
Action[A]: Remediation under way.
State: Texas;
Installation: McGregor Naval Weapons Industrial Reserve Plant;
Service: Navy;
Installation type: Transferred;
Media: Groundwater; Soil; Surface water;
Highest detection (ppb): 91,000(GW); 1,800(S); 6,600(SW);
Action[A]: Remediation completed.
State: Texas;
Installation: Red River Army Depot;
Service: Army;
Installation type: Active;
Media: Groundwater Other;
Highest detection (ppb): 37.4 252;
Action[A]: Ongoing monitoring.
State: Utah;
Installation: Hill Air Force Base;
Service: Air Force;
Installation type: Active;
Media: Groundwater Soil;
Highest detection (ppb): 39.9 86,000;
Action[A]: Ongoing monitoring.
State: Virginia;
Installation: Dahlgren Naval Surface Facility;
Service: Navy;
Installation type: Active;
Media: Groundwater; Sediment; Soil; Surface water;
Highest detection (ppb): 2,700(GW); 120(Sed); 3,100(S); 230(SW);
Action[A]: Risk assessment under way.
State: Virginia;
Installation: Radford Army Ammunition Plant;
Service: Army;
Installation type: Active;
Media: Groundwater;
Highest detection (ppb): 127;
Action[A]: Ongoing monitoring; Planned action based on permit
modification.
State: Virginia;
Installation: Yorktown Naval Weapons Station;
Service: Navy;
Installation type: Active;
Media: Groundwater;
Highest detection (ppb): 160;
Action[A]: Ongoing monitoring; Risk assessment under way.
State: Washington;
Installation: Camp Bonneville;
Service: Army;
Installation type: Transferred;
Media: Groundwater;
Highest detection (ppb): 490;
Action[A]: Contaminated soil removed; Ongoing monitoring.
State: West Virginia;
Installation: Allegany Ballistics Laboratory;
Service: Navy;
Installation type: Active;
Media: Groundwater; Soil; Surface water; Wastewater;
Highest detection (ppb): 34,900(GW); 35,000(S); 690(SW); 1,900,000(WW);
Action[A]: Remediation planned; Remediation planned; Groundwater
source suspected; Remediation under way.
Sources: GAO analysis of EPA and DOD data.
Notes: DOD officials said that these data do not represent a
comprehensive list of actions DOD has taken in response to perchlorate
releases because the database only has information on cleanup
activities at installations where perchlorate is a primary contaminant
of concern.
According to DOD officials, EPA regions and states typically set
higher screening levels for perchlorate in soil. Therefore, DOD's 15
parts per billion screening level is not applicable to soil.
[A] Ongoing monitoring means monitoring that occurs on a regular
basis; "risk assessment" includes both site investigations and risk
assessments; "consultation with regulators" means discussions between
installation officials and EPA or state regulators regarding the
actions needed to clean up perchlorate.
[B] BRAC means Base Realignment and Closure and describes an
installation that has been closed as part of the process to realign
the military infrastructure to match the size of the military in terms
of personnel and equipment.
[C] According to DOD officials, in March 2003, perchlorate was
detected in a soil sample at 5,580 parts per billion using EPA Method
314.0, but additional samples taken in 2009 using EPA Method 6850 did
not detect perchlorate above the method detection limit. Consultation
with state regulators resulted in agreement that the initial detection
of 5,580 parts per billion was likely attributable to the
misapplication of EPA Method 314.0 to soil samples and that, because
of the 2009 sampling results, no action is required, DOD officials
said.
[End of table]
[End of section]
Appendix IV: Comments from the Department of Defense:
Note: GAO comments supplementing those in the report text appear at
the end of this appendix.
Office Of The Under Secretary Of Defense:
Acquisition, Technology And Logistics:
3000 Defense Pentagon:
Washington, DC 20301-3000:
July 26, 2010:
Mr. John B. Stephenson:
Director, Director, Natural Resources and Environment:
U.S. Government Accountability Office:
441 G Street, N.W.
Washington, DC 20548:
Dear Mr. Stephenson:
This is the Department of Defense (DoD) response to the GAO Draft
Report GAO-10-769, "Perchlorate: Occurrence is Widespread but at
Varying Levels; Federal Agencies Have Taken Some Actions to Respond to
and Lessen Releases," dated July 6, 2010 (GAO Code 361105).
The Department believes that the GAO report omitted a number of
important facts and conclusions resulting from state and DoD
initiatives. Although GAO made no recommendations in this report, we
believe the enclosed comments will help provide additional perspective
and ensure that the Congress and the public better understand the
risks related to perchlorate and DoD actions taken to ensure
protection of human health and the environment.
Sincerely,
Signed by:
John Conger:
Assistant Deputy Under Secretary of Defense:
(Installations and Environment)
Enclosure: As stated:
[End of letter]
GAO Draft Report Dated July 2010:
GAO-10-769 (GAO Code 361105):
"Perchlorate: Occurrence Is Widespread But At Varying Levels; Federal
Agencies Have Taken Some Actions To Respond To And Lessen Releases"
Department Of Defense Comments: To The GAO Report:
Major Issues:
1. The report mentions the California Prioritization Protocol, a
collaborative effort between the State and DoD, but fails to provide
the major conclusions from over two years of effort. [See comment 1]
As a result of concern over widespread perchlorate contamination in
California, DoD and California regulators collaboratively developed a
screening procedure for DoD sites called the California Perchlorate
Prioritization Protocol. Using the protocol, DoD and the California
Department of Toxic Substances Control and the State Water Resources
Control Board screened 924 DoD sites that had the potential for
perchlorate releases. No risks to public water supplies were
identified.
A December 2008 Environmental Management article jointly written by
DoD and California regulatory personnel, states that the "protocol,
when taken together with other DoD sampling and remedial efforts, as
well as sampling efforts by other parties, reveals that the sources of
perchlorate detections in water wells appears to be far more
complicated than originally suspected. Based on the results of the
prioritization, the current regulatory standards for perchlorate,
sampling results to date, as well as actions taken to manage new
releases and remediate known perchlorate releases, it appears that DoD
installations/FUDS are not significantly impacting California public
drinking water wells."
2. The report mentions that Massachusetts found perchlorate in nine of
600 water systems tested but fails to mention that none of these
detections were related to military sources. The report also fails to
describe the perchlorate sources that were determined by the State.
[See comment 2]
In a March 14, 2005 letter to EPA Assistant Administrator Ben
Grumbles, Mr. Robert Golledge, Commissioner, Massachusetts Department
of Environmental Protection stated the following:
"In March 2004, the Department initiated the process to establish a
drinking water maximum contaminant level (MCL) for perchlorate by
promulgating regulations requiring all public water supplies to test
for perchlorate. Several rounds of sampling have been completed
statewide. Nine public water supplies have detected perchlorate, seven
of the nine have perchlorate ranging from just below 1 ppb to slightly
above 3 ppb. However, two water supplies had greater than 45 ppb, one
as high as 1300 ppb. When confronted with the perchlorate plume at
Massachusetts Military Reservation in 2001, most thought the primary
source of perchlorate contamination was the result of military
training activities. None of the nine water supplies that have tested
positive for perchlorate in Massachusetts appear to have any
connection to military bases or activities."
The report states that Massachusetts officials were able to "determine
the localized sources of high concentrations of perchlorate" but does
not identify those sources. An example of a source identified by the
state is blasting activities from road construction.
3. The report fails to mention Department of Commerce data, provided
to GAO by DoD, describing the large amount of perchlorate imported
into the U.S. primarily for fireworks and used in an uncontrolled
manner over large areas. [See comment 3]
This data provides perspective on DoD's use versus imports for
commercial use. According to the American Pyrotechnics Association,
278.2 million pounds of fireworks were consumed in the U.S. annually
over a recent 5 year period, approximately 14 million pounds of which
is perchlorate.
DoD purchases of perchlorate compounds in weapon systems was between
6 - 8 million pounds over a similar 5 year period. Much of this
perchlorate is stored in missiles and munitions or used in overseas
combat areas.
4. By leaving out various factors, the report's review of historical
sampling data leads the reader to believe that the public health risk
of perchlorate from DoD activities is greater than it actually is.
[See comment 4]
First, when identifying samples that exceeded screening levels, the
report did not note those detections that have since been remediated
or assessed as requiring no further action. Such sites present no
risk. Thus, by reporting all historical detections with no
explanation, the report makes it appear that all detections present a
risk. [See comment 5]
Second, the report identifies all DoD perchlorate samples over 15 ppb
regardless of whether the sample was taken from drinking water or
soil. EPA's Public Health Advisory screening level for drinking water
is 15 ppb. EPA Regions and states typically set much higher risk
screening levels for soils. For example, a widely-used EPA Regional
Screening Level for perchlorate in soil is 55 mg/kg or 55,000 ppb. By
citing soil samples with perchlorate levels above the screening level
for drinking water, the report inflates the appearance of risk to
public health. [See comment 6]
Third, the report does not take into account other risk factors.
Screening levels are only a starting point. Risk is determined more
definitively through a baseline human health risk assessment. [See
comment 7]
Fourth, the report does not offer an overall perspective of the DoD
sample results or a full understanding of risk. Based on DoD risk
assessments and over 50,000 samples taken at or around DoD
installations in the U.S., DoD believes that there are no DoD releases
of perchlorate currently presenting a human health threat to public
drinking water supplies. [See comment 8]
Finally, the report does not take into account DoD efforts to verify
the conclusions we have reached from our sampling program with state
and federal regulators. [See comment 9] For example, in an April 2009
letter to EPA's Director of the Federal Facilities Restoration and
Reuse office, DoD stated: "Based on our data and discussion with the
Military Services, we believe that appropriate actions are being
taken, in consultation with regulators, at all sites with releases."
The letter further states: "We want to ensure that there are no DoD
releases of perchlorate that would cause an exposure in current
drinking water at levels above a state MCL or the EPA Health Advisory
Level of 15 ppb. Based on information and data currently available, we
do not believe any of our installations or FUDS are in this category
at this time. The main purpose of this letter is to determine if you
agree with this characterization and whether you have any additional
information that would help inform our characterization."
After consultation with EPA Regions and EPA program offices, EPA's
Director of the Federal Facilities Restoration and Reuse office
replied in a March 2010 letter. Because EPA did not have data from all
possible sites, EPA could not confirm whether or not there have been
releases of perchlorate from DoD-owned facilities that resulted in
exposure in drinking water at levels above a state standard or the
Interim Health Advisory Level for perchlorate of 15 ppb. However, the
letter states: "My office is unaware of information reported to EPA
that would indicate such releases."
In summary, by not taking into account all the factors associated with
the DoD perchlorate sampling program, the report leads the reader to
believe that the public health risk of perchlorate from DoD activities
is greater than it is. [See comment 10]
5. The report fails to provide the conclusions of the EPA Office of
Inspector General's report on perchlorate. The conclusions are
significant to understanding perchlorate risks and risk management
options. [See comment 11]
The EPA Office of Inspector General's (OIG) Report "Scientific
Analysis of Perchlorate", Report No. 10-P-0101, April 19, 2010, has
significant findings that GAO fails to provide. The GAO report simply
states that the EPA OIG "released a report that reviewed and critiqued
the risk assessment process and procedures used by EPA to develop and
derive a perchlorate reference dose".
The conclusions of the EPA OIG report were:
"Based on our scientific analysis, perchlorate is only one of several
chemicals that stress the thyroid's ability to uptake iodide. The
other sodium iodide symporter (NIS) stressors include thiocyanate,
nitrate, and the lack of iodide. All four of these NIS stressors meet
EPA's risk assessment guidance for conducting a cumulative risk
assessment using the dose-addition method. Our analysis implemented a
cumulative risk assessment that found the following: 1) the risk from
each of the four NIS stressors is not equal; 2) EPA's perchlorate RfD
is conservative and protective of human health, and further reducing
the perchlorate exposure below the RID does not effectively lower
risk; 3) increasing maternal total iodide intake to healthy levels
will reduce the frequency and severity of permanent mental deficits in
children; and 4) correcting moderate and mild iodide deficiency
occurring in about 29 percent of the U.S. pregnant and nursing
population is the most effective approach for reducing risk."
Additional Comments.
Title Page - In the title, the use of the term "Some" is misleading.
DoD believes it demonstrated to GAO that appropriate actions are being
taken at all installations in coordination with regulators. The term
"Some" does not accurately reflect the scope and completeness of the
DoD sampling, assessment, and remediation actions. [See comment 12]
Executive Summary and Page 11-12 states: "DoD reported perchlorate
detections at 284 of its installations, or almost 70 percent of the
407 installations sampled from fiscal years 1997 through 2009...."
At low levels, perchlorate can be found almost everywhere. The report
overstates the situation by essentially equating every detection
greater than absolute zero as a detection of significance. [See
comment 14]
Page 3: The report fails to mention the use of sodium hypochlorite in
home septic systems and wastewater treatment plants as a source of
perchlorate in drinking water. [See comment 14. Page numbers in the
draft report may differ from those in this report]
The State of Massachusetts' study, cited in the GAO report, identified
home septic systems as such a source.
Page 16: The report could have identified other means by which
perchlorate may enter the food chain other than through contact with
contaminated water. Atmospheric deposition and photosynthesis in areas
with high ground ozone are also suspected sources and are being
researched.
Page 20: From the manner by which the report presents DoD's sampling
information, the reader could draw the conclusion that 137
installations (361 minus 224) did not sample and had no explanation
for not sampling. This conclusion is not correct. The report
inappropriately excludes data that exists only in textual narrative
form (e.g., Air Force and Army documentation prior to 2007 is captured
in DoD's data base as text rather than as an MS Excel data field). DoD
has sampled at all installations where there have been releases or
suspected releases of perchlorate. [See comment 15]
Page 22: Regarding Redstone Arsenal. In lieu of GAO's summary, it
would be more correct to state: "The Army has identified and planned a
number of soil removal actions to remove contaminated soils that serve
as an on-going source of perchlorate to groundwater. The Army is
drafting a memorandum of understanding (MOU) with the City of
Huntsville whereby the City will consult with the Army before
approving any well installation requests for areas with the potential
for perchlorate contamination." GAO stated that "EPA officials told us
that the current cleanup documentation provided to the regulatory
agencies indicates that he Army does not intend to remediate
perchlorate in groundwater at Redstone." However, the Army is in the
process of obtaining regulatory approval for further site
investigation on some perchlorate contaminated areas. The
investigations could determine the need for and feasibility of
remedial action. [See comment 16]
Page 24: GAO has oversimplified and unintentionally mischaracterized
the Kirtland AFB issue. The New Mexico Environmental Department (NMED)
has attempted to enforce a 4 ppb perchlorate standard on its
permittees despite no promulgated regulatory standard. Kirtland AFB
formally notified the NMED Groundwater Quality Bureau of perchlorate
detection in a letter from the Base Commander dated 1 March 2005. It
was not until 23 June 2009, however, that NMED Hazardous Waste Bureau
issued a letter to Kirtland AFB to begin investigation/cleanup of the
perchlorate at the site. GAO's draft report currently states:
"According to the Air Force, it is discussing with New Mexico
regulators whether cleanup should be conducted under CERCLA or the
state's RCRA authority". It is more accurate to say: "On-going legal
discussions continue in order to resolve a disagreement over whether
further actions should be conducted under CERCLA pursuant to the DoD
perchlorate policy, or under the state's RCRA authority. In the
meantime, the Air Force has submitted a Site Investigation Work Plan
to the state and has begun investigating the site; no pathway to
public or private drinking water sources has been demonstrated to
date." [See comment 17]
Page 44, Appendix 11 - Mather and McClellan AFBs are closed BRAC bases
and should be referred to as Former Mather and Former McClellan AFBs.
Page 46: Appendix III. [See comment 18]
Camp Edwards/MMR should be attributed to both Air Force and Army. [See
comment 19]
The appendix lists McAlester Ammunition Plant, OK, as having
remediation underway, and indicates groundwater remediation — this is
not correct. McAlester has ongoing monitoring for perchlorate in
groundwater. McAlester has an effluent treatment system for
perchlorate for its perchlorate loading and packing operations. [See
comment 20]
Under the Action column for China Lake Naval Air Weapons Station, it
would be more correct to indicate that remediation is unnecessary
based on risk assessment results. [See comment 20]
The Action column for El Centro Naval Air Facility should indicate
that the 15 ppb PRG is not applicable to soil. [See comment 20]
The Action column for NOLF San Nicolas Island should indicate that a
Range Condition Assessment is underway. [See comment 20]
The Action column for NWS Seal Beach Detachment Fallbrook should
indicate that the 15 ppb PRG is not applicable to soil.
The following are GAO's comments on the Department of Defense's letter
dated July 26, 2010, and provided by the Assistant Under Secretary of
Defense (Installations and Environment).
GAO Comments:
1. We revised the text to provide some additional detail about the
California Prioritization Protocol.
2. We disagree with DOD's comment that, while the report mentions the
results of perchlorate sampling in Massachusetts, it fails to mention
that none of these detections were related to military sources and to
describe the perchlorate sources that were determined by the state.
This information appears on page 31 in the section of the report
describing Massachusetts' actions to regulate perchlorate.
3. Information on the amount of perchlorate imported primarily for
fireworks compared with the amount of perchlorate used by DOD is
beyond the scope of this report, which focuses on the extent and
likely sources of perchlorate occurrence, and federal agency actions
to respond to and lessen releases. Although an organization may use a
significant amount of perchlorate for a specific purpose, the quantity
used is not necessarily indicative of the amount of perchlorate
released into the environment.
4. A discussion of the public health risks of perchlorate is beyond
the scope of this report. The scientific community is still debating
health risks associated with perchlorate.
5. Appendix III describes the actions DOD has taken to respond to
perchlorate releases and notes when DOD's assessment concluded that no
further action is required.
6. We revised appendix III to note that DOD does not apply the 15
parts per billion screening level to soil.
7. A discussion of the public health risks of perchlorate is beyond
the scope of this report.
8. This report draws no conclusions regarding the human health threat
that DOD releases of perchlorate currently pose to public drinking
water supplies because it is beyond the scope of our work.
9. A discussion of DOD's efforts to verify the conclusions from its
sampling program with state and federal regulators is beyond the scope
of our report.
10. A discussion of the public health risks of perchlorate is beyond
the scope of this report.
11. Because a discussion of the public health risks of perchlorate is
beyond the scope of this report, we did not evaluate or report on the
conclusions of the Inspector General's report in this regard.
12. We disagree with DOD's comment that our title is misleading. DOD
is only one of three federal agencies whose actions we describe in the
report and, therefore, we believe that the title is appropriate.
13. The report does not characterize the significance of detections.
Rather, we note the range of detections at DOD installations and the
number of installations with detections above 15 parts per billion--
DOD's current threshold level for conducting further investigation
when perchlorate is detected in water to determine whether additional
action is warranted.
14. The report mentions that sodium hypochlorite solutions used as a
disinfectant in water and water treatment plants is a source of
perchlorate. See pages 2 and 32.
15. We revised the text to clarify the DOD sampling information
presented in the report, which includes the results of GAO's analysis
of data that exists only in narrative format.
16. We revised the text to include the Army's description of actions
taken at Redstone Arsenal.
17. We revised the text to clarify the Air Force's position on the
status of actions being taken to respond to perchlorate at Kirtland
Air Force Base.
18. We revised appendix II to show that Mather and McClellan Air Force
Bases are closed.
19. We revised appendix III to attribute Camp Edwards/Massachusetts
Military Reservation to both the Air Force and the Army.
20. In appendix III, we revised the action column for McAlester
Ammunition Plant, China Lake Naval Air Weapons Station, El Centro
Naval Air Facility, NOLF San Nicolas Island, and NWS Seal Beach
Detachment Fallbrook to reflect the information provided by DOD.
[End of section]
Appendix V: GAO Contact and Staff Acknowledgments:
GAO Contact:
John B. Stephenson, (202) 512-3841, or stephensonj@gao.gov.
Staff Acknowledgments:
In addition to the individual named above, Stephen Secrist, Assistant
Director; Elizabeth Beardsley; Mark Braza; N'Kenge Gibson; Mitchell
Karpman; Susan Malone; Madhav Panwar; Jeremy Sebest; Ben Shouse;
Matthew Tabbert; and Kiki Theodoropoulos made key contributions to
this report.
[End of section]
Footnotes:
[1] An oxidizer is a substance that yields oxygen readily to cause the
combustion of other materials.
[2] The Jet Propulsion Laboratory is a federally funded research and
development center managed by the California Institute of Technology
for NASA.
[3] Codified as amended at 42 U.S.C. § 300g-1(b)(1).
[4] EPA defines a reference dose as an estimate of a daily oral
exposure for a given duration to the human population (including
susceptible subgroups) that is likely to be without an appreciable
risk of deleterious health effects during a lifetime. Reference doses
are generally expressed as milligrams per kilogram of body weight per
day.
[5] EPA calculates the drinking water equivalent level--expressed in
parts per billion--assuming that an adult weighing 70 kilograms (or
154 pounds) consumes 2 liters of water per day, and all perchlorate
exposure comes from drinking water.
[6] EPA determined that there was too much scientific uncertainty to
establish a provisional reference dose as a single point and,
therefore, established a range.
[7] The 800 small public water systems represented about 1 percent of
the approximately 67,000 systems serving 10,000 or fewer people from
which the sample was drawn.
[8] National Research Council, Health Implications of Perchlorate
Ingestion (Washington, DC.: 2005).
[9] A preliminary remediation goal is a chemical-specific
concentration goal for a specific medium (e.g., soil, sediment, and
water) that serves as a target to use during the initial development,
analysis, and selection of cleanup alternatives.
[10] Pub. L. No. 96-510 (1980), codified as amended at 42 U.S.C. §
9601 et seq. (2010). CERCLA, better known as Superfund, provides EPA
with certain oversight authority for cleaning up releases of hazardous
substances, pollutants, or contaminants on federal and private
properties.
[11] EPA, Office of Inspector General Scientific Analysis of
Perchlorate, Report No. 10-P-0101 (Washington, D.C.: Apr. 19, 2010).
[12] One federal court has ruled that perchlorate contaminating a site
was a hazardous substance under CERCLA. Castaic Lake Water Agency v.
Whittaker Corp, 272 F. Supp. 2d 1053 (C.D. Cal. 2003). The court held
that perchlorate is a hazardous waste under the Resource Conservation
and Recovery Act and, as the definition of hazardous substances under
CERCLA includes hazardous waste under the Resource Conservation and
Recovery Act, perchlorate is therefore a hazardous substance under
CERCLA.
[13] State guidance levels may be used to determine remediation goals
in the context of a CERCLA cleanup. See 40 C.F.R. § 300.430(e)(2)(i)
(2010).
[14] CERCLA applies federal drinking water standards to potential
sources to the same extent as to existing sources of drinking water
when establishing site cleanup requirements. While there is currently
no such federal drinking water standard for perchlorate, this
provision indicates the general intent to protect potential water
supplies, as well as present ones. In addition, some states have
established water quality standards for groundwater whether or not it
is currently used as a drinking water source, often reflecting state
positions that most groundwater is considered potential drinking
water. For example, New Jersey has established a standard of 5 parts
per billion for perchlorate in groundwater classified as an existing
or potential drinking water source; this standard is generally
applicable to groundwater cleanups.
[15] Executive Order 12580, 52 Fed. Reg. 2923 (Jan. 23, 1987).
[16] Superfund Amendments and Reauthorization Act, § 211, 10 U.S.C. §§
2701-07 (2010).
[17] 42 U.S.C. §§ 6901-6992k (2010).
[18] 42 U.S.C. §§ 300f-300j-26 (2010).
[19] 33 U.S.C. §§ 1251-1387 (2010).
[20] According to EPA, primary pathways for human exposure to
perchlorate are ingestion of food and contaminated drinking water.
[21] See GAO, Perchlorate: A System to Track Sampling and Cleanup
Results Is Needed, [hyperlink, http://www.gao.gov/products/GAO-05-462]
(Washington, D.C.: May 20, 2005).
[22] As used here, "sediment" means matter that settles to the bottom
of water.
[23] The Santa Susana Field Laboratory site is divided into four areas
that are under different ownership. Boeing owns part of Area I, and
all of Areas III and IV. NASA owns Area II and owns 42 acres of Area
I. From 1956 to 1988, the Energy Technology Engineering Center, which
is located in Area IV, was used by Rocketdyne and DOE for nuclear
energy research and development. The Energy Technology Engineering
Center is now closed.
[24] Perched groundwater is groundwater that sits above a main body of
groundwater and is separated by a layer of geologic material (such as
clay, silts, or shale) that acts as a barrier to downward flow.
[25] Arizona Department of Environmental Quality, Perchlorate in
Arizona: Occurrence Study of 2004 (2004).
[26] A health-based guidance level reflects the maximum concentration
of a contaminant in drinking water that is unlikely to result in
adverse health effects during long-term exposure. Arizona reduced its
health based guidance level for perchlorate to 11 parts per billion in
2005 after EPA revised its reference dose.
[27] W. Andrew Jackson et al., Distribution and Potential Sources of
Perchlorate in the High Plains Region of Texas (August 2004).
[28] J.K. Böhlke et al., "Perchlorate isotope forensics," Analytical
Chemistry, vol. 77, no. 23 (2005); L.N. Plummer, J.K. Böhlke, and M.W.
Doughten, "Perchlorate in Pleistocene and Holocene groundwater in
North-Central New Mexico," Environmental Science and Technology, vol.
40, no. 6 (2006); and N.C. Sturchio et al., "Oxygen and chlorine
isotopic fractionation during perchlorate biodegradation: laboratory
results and implications for forensics and natural attenuation
studies," Environmental Science and Technology, vol. 41, no. 8 2007).
[29] J.K. Böhlke et al., "Atacama Perchlorate as an Agricultural
Contaminant in Groundwater: Isotopic and Chronologic Evidence from
Long Island, New York," Environmental Science and Technology, vol. 43,
no. 15 (2009).
[30] For more information on FDA's Total Diet Study, see [hyperlink,
http://www.fda.gov/Food/FoodSafety/FoodContaminantsAdulteration/TotalDie
tStudy/default.htm].
[31] In each of four geographic regions of the United States (West,
North Central, South, and Northeast), FDA took samples of each of 285
food items and, for 211 of those items, found perchlorate in at least
one of the samples.
[32] Clarence W. Murray et al., "U.S. Food and Drug Administration's
Total Diet Study: Dietary intake of perchlorate and iodine," Journal
of Exposure Science and Environmental Epidemiology, vol. 18 (2008).
[33] Joshua G. Schier et al., "Perchlorate exposure from infant
formula and comparisons with the perchlorate reference dose," Journal
of Exposure Science and Environmental Epidemiology, vol. 1-7 (2009).
[34] Charles A. Sanchez et al., "Perchlorate exposure from food crops
produced in the lower Colorado River region," Journal of Exposure
Science and Environmental Epidemiology, vol. 1-10 (2008).
[35] P.K. Dasgupta et al., "Perchlorate in the United States: Analysis
of Relative Source Contributions to the Food Chain," Environmental
Science and Technology, vol. 40, no. 21 (2006).
[36] Richard T. Wilkin et al., "Perchlorate Behavior in a Municipal
Lake Following Fireworks Displays," Environmental Science and
Technology, vol. 41, no. 11 (2007).
[37] An isotopic signature is the distribution of certain chemical
elements and their respective ratio of isotopes in a chemical compound.
[38] The statute also provides exemptions from liability for parties
meeting certain characteristics, as well as statutory defenses.
[39] In 2005, DOD established the operational range assessment program
to implement procedures to assess the potential environmental impacts
of military munitions use on operational ranges. An operational range
is an area that is currently in service and is regularly being used
for weapons training using live ammunition or such a range that is not
currently being used but that is still considered by the military to
be a potential range area.
[40] The procedure included steps to identify and prioritize the
investigation of areas on DOD installations and formerly used defense
sites (1) where the presence of perchlorate is likely based on
previous and current defense-related activities and (2) near drinking
water sources where perchlorate was found.
[41] The protocol excluded RCRA sites, DOD operational ranges, sites
greater than 5 miles from a public drinking water well, releases that
impact media other than drinking water wells, and non-DOD sites,
including contractor-owned facilities.
[42] For more information on the California Prioritization Protocol,
see Laurie Racca et al., Attention to Protocol: How a State/Federal
Partnership Defused Tensions over Perchlorate, EM Magazine (December
2008).
[43] DOD has used various threshold levels at different times in the
past, reflecting EPA's reference doses. At sites that have undergone
remediation followed by 5-year reviews, DOD may review perchlorate
concentrations to determine if they exceed current thresholds.
However, at sites where DOD made a determination that no further
action is required, based on thresholds in use at the time, DOD has
not necessarily conducted subsequent reviews of the site's perchlorate
concentrations when the thresholds for action have been lowered.
[44] Each installation conducting cleanup activities is required to
have a management action plan to guide environmental restoration,
which is to contain this list, among other things.
[45] Ion exchange treats perchlorate by using resins that attract
perchlorate and exchange their ions to break down the perchlorate.
According to federal officials and researchers we contacted, ion
exchange is the preferred technology to remediate drinking water and
other media at low concentrations. Another treatment option is
bioremediation, which uses bacteria to break down perchlorate to a
component of table salt. It is used to treat high concentrations of
perchlorate.
[46] We have recently found that Redstone Arsenal is one of the four
long-standing DOD installations on the National Priorities List for
which DOD has not signed an Interagency Agreement, even though it is
required under CERCLA. See GAO, Superfund: Interagency Agreements and
Improved Project Management Needed to Achieve Cleanup Progress at Key
Defense Installations, GAO-10-348 (Washington, D.C.: Jul. 15, 2010).
[47] According to DOD officials, some of this funding has been
directed by Congress or congressional committees, while some has been
voluntary.
[48] According to DOD, the Strategic Environmental Research and
Development Program is DOD's environmental science and technology
program and is conducted in partnership with DOE and EPA, while the
Environmental Security Technology Certification Program promotes
innovative, cost-effective environmental technologies through
demonstration and validation at DOD sites.
[49] An aquifer is an underground bed or layer of permeable rock,
sediment, or soil that yields water.
[50] According to DOE officials, in 2007, DOE installed two monitoring
wells in anticipation of installing a groundwater treatment system and
encountered higher levels of perchlorate than it originally detected
in 1999. Subsequently, DOE installed injection wells for the treatment
system downstream from the monitoring wells and encountered
concentrations of perchlorate up to 3,090 parts per billion.
[51] According to DOE officials, the highest concentrations of
perchlorate in groundwater were found at the Explosive Ordnance
Disposal Hill Well, which is shared with Kirtland Air Force Base, and
the state of New Mexico is requiring the Air Force to conduct further
investigation of perchlorate at the site.
[52] According to DOD, all funding for perchlorate substitutes has
been voluntary.
[53] The California Department of Public Health was formerly the
California Department of Health Services. For purposes of this report,
we will use the department's current name.
[54] An action level--now called a notification level--is the level at
which public water companies must report the presence of a contaminant
to the Department of Public Health. The department may recommend that
utilities take steps to remove the water source from service if
average contaminant levels exceed between 10 times to 100 times the
action level, depending on the chemical.
[55] U.S. EPA Method 314.0.
[56] California Health and Safety Code, section 116365(c).
[57] M.A. Greer et al., "Health Effects Assessment for Environmental
Perchlorate Contamination: The Dose Response for Inhibition of
Thyroidal Radioiodine Uptake in Humans," Environmental Health
Perspectives, vol.110, no. 9 (2002).
[58] OEHHA's normal process calls for one round of peer review by the
university. However, Lockheed Martin and Kerr McGee had filed a
lawsuit against OEHHA over whether the two firms could request and
obtain a second peer review of OEHHA's draft review document. The
judge ruled that procedural requirements in state law required OEHHA
to accept the firms' request and issued a court order requiring OEHHA
to finalize the public health goal within 60 days of the completion of
the second peer review.
[59] National Research Council, Health Implications of Perchlorate
Ingestion (Washington, D.C.: 2005).
[60] According to EPA officials, perchlorate that no longer displays
the characteristic of ignitability is treated as nonhazardous waste.
[61] In a composite-lined portion of a nonhazardous landfill, a
flexible synthetic membrane is used to line the bottom and sides of
the landfill to protect groundwater and underlying soil from
contamination.
[62] For example, certain perchlorate-containing materials, such as
consumer products and irrigation water, are excluded from these
regulations, as is any perchlorate-containing material that is being
managed in accordance with hazardous waste rules or in a cleanup under
oversight of a regulatory agency. Cal. Code Regs. tit. 22, § 67384.2-3
(2010).
[63] None of the nine water supplies appeared to have any connection
to military activities. Instead, perchlorate contamination was
associated with the launching of fireworks and the use of flares,
certain blasting agents, and hypochlorite solutions to disinfect
drinking water. Perchlorate was also found to be discharged from an
industrial source at extremely high levels.
[64] National Research Council, Health Implications of Perchlorate
Ingestion (Washington, D.C.: 2005).
[65] Andrea B. Kirk et al., "Perchlorate and Iodide in Dairy and
Breast Milk," Environ. Sci. Technol., vol. 39, no. 7 (2005).
[66] For more information, see [hyperlink,
http://www.fda.gov/Food/FoodSafety/FoodContaminantsAdulteration/Chemical
Contaminants/Perchlorate/ucm077685.htm].
[67] The lowest-observed-adverse-effect level is the lowest dose in a
toxicity study resulting in adverse health effects.
[68] M.A. Greer et al., "Health Effects Assessment."
[69] Some public water systems will use a blending station to mix
perchlorate-impacted water with clean water to achieve regulatory
compliance with drinking water standards.
[70] EPA does not maintain an up-to-date list of states that have
adopted guidance levels for perchlorate. However, we were able to
obtain information on state actions from EPA regional officials and
the Association of State Drinking Water Administrators, which we then
verified with state environmental officials.
[End of section]
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